# Bank of New York Mellon Corp (BNY) FY 2025 MD&A Verbatim Item 7 Management's Discussion and Analysis from Bank of New York Mellon Corp's 10-K for fiscal year 2025. SEC filing source: https://www.sec.gov/Archives/edgar/data/1390777/000139077726000033/bk-20251231.htm Accession: 0001390777-26-000033 Filing date: 2026-02-25 Report date: 2025-12-31 Extracted from a substantive MD&A body after the formal Item 7 span was a TOC or reference stub. Source document followed from filing index: bk-20251231_d2.htm. Confidence: high Company profile: /company/BNY/ All MD&A years: /company/BNY/mda/ Previous year: /company/BNY/mda/fy2024/ (FY 2024) Overview BNY is a global financial services platforms company at the heart of the world’s capital markets. For more than 240 years BNY has partnered alongside clients, using its expertise and platforms to help them operate more efficiently and accelerate growth. Today BNY serves over 90% of Fortune 100 companies and nearly all the top 100 banks globally. BNY supports governments in funding local projects and works with over 90% of the top 100 pension plans to safeguard investments for millions of individuals. As of Dec. 31, 2025, BNY oversees $59.3 trillion in assets under custody and/or administration and $2.2 trillion in assets under management. BNY is the corporate brand of The Bank of New York Mellon Corporation (NYSE: BK). Headquartered in New York City, BNY has been named among Fortune’s World’s Most Admired Companies and Fast Company’s Best Workplaces for Innovators. Additional information is available on www.bny.com. Follow on LinkedIn or visit the BNY Newsroom for the latest company news. BNY has three business segments, Securities Services, Market and Wealth Services and Investment and Wealth Management, which offer a comprehensive set of capabilities and deep expertise across the investment life cycle, enabling the Company to provide solutions to buy-side and sell-side market participants, as well as leading institutional and wealth management clients globally. The diagram below presents our three business segments and lines of business, with the remaining operations in the Other segment. [[GREPCENT_TABLE]] [["","","","","","","The Bank of New York Mellon Corporation"],["Securities Services","","","Market and Wealth Services","","","Investment and Wealth Management"],["","","Asset Servicing","","","","Pershing","","","","Investment Management"],["","","Issuer Services","","","","Payments andTrade (a)","","","","Wealth Management"],["","","","","","","","","Clearance and Collateral Management"]] [[/GREPCENT_TABLE]] (a)    Formerly Treasury Services. For additional information on our business segments, see “Review of business segments” and Note 23 of the Notes to Consolidated Financial Statements. Summary of financial highlights We reported net income applicable to common shareholders of $5.3 billion, or $7.40 per diluted common share, in 2025, including the net negative impact of notable items. Notable items in 2025 include disposal gains, severance expense, litigation reserves and the net impact of adjustments for the Federal Deposit Insurance Corporation (“FDIC”) special assessment. Excluding notable items, net income applicable to common shareholders was $5.4 billion (Non-GAAP), or $7.50 (Non-GAAP) per diluted common share, in 2025. In 2024, net income applicable to common shareholders was $4.3 billion, or $5.80 per diluted common share, including the negative impact of notable items. Notable items in BNY 3 Results of Operations (continued) 2024 include severance expense, litigation reserves and the net impact of adjustments for the FDIC special assessment. Excluding notable items, net income applicable to common shareholders was $4.5 billion (Non-GAAP), or $6.03 (Non-GAAP) per diluted common share, in 2024. The highlights below are based on 2025 compared with 2024, unless otherwise noted. •Total revenue increased 8%, primarily reflecting: •Fee revenue increased 6%, primarily reflecting net new business and higher client activity, higher market values and the favorable impact of a weaker U.S. dollar, partially offset by the mix of AUM flows. (See “Fee and other revenue” beginning on page 5.) •Investment and other revenue increased primarily reflecting disposal gains and net gains on other investments. (See “Fee and other revenue” beginning on page 5.) •Net interest income increased 15%, primarily reflecting the reinvestment of maturing investment securities at higher yields and balance sheet growth, partially offset by deposit margin compression. (See “Net interest income” beginning on page 7.) •The provision for credit losses was a benefit of $32 million, primarily driven by improvements in commercial real estate exposure and changes in the macroeconomic forecast. (See “Consolidated balance sheet review – Allowance for credit losses” beginning on page 32.) •Noninterest expense increased 3%, primarily reflecting higher investments, employee merit increases, higher revenue-related expenses and the unfavorable impact of the weaker U.S. dollar, partially offset by efficiency savings. Excluding notable items, noninterest expense also increased 3% (Non-GAAP). (See “Noninterest expense” on page 10.) •Effective tax rate of 20.9% in 2025. (See “Income taxes” on page 10.) •Return on common shareholders’ equity (“ROE”) was 13.9% for 2025. Excluding notable items, the adjusted ROE was 14.1% (Non-GAAP) for 2025. •Return on tangible common shareholders’ equity (“ROTCE”) was 26.1% (Non-GAAP) for 2025. Excluding notable items, the adjusted ROTCE was 26.4% (Non-GAAP) for 2025. See “Supplemental Information – Explanation of GAAP and Non-GAAP financial measures” beginning on page 111 for reconciliations of the Non-GAAP measures. Metrics •AUC/A totaled $59.3 trillion at Dec. 31, 2025 compared with $52.1 trillion at Dec. 31, 2024. The 14% increase primarily reflects client inflows, higher market values and the favorable impact of the weaker U.S. dollar. (See “Fee and other revenue” beginning on page 5.) •AUM totaled $2.18 trillion at Dec. 31, 2025 compared with $2.03 trillion at Dec. 31, 2024. The 7% increase primarily reflects higher market values and the favorable impact of the weaker U.S. dollar, partially offset by cumulative net outflows. (See “Review of business segments – Investment and Wealth Management business segment” beginning on page 16.) Capital and liquidity •Our CET1 ratio calculated under the Standardized Approach was 11.9% at Dec. 31, 2025 and 11.2% at Dec. 31, 2024. The increase was primarily driven by capital generated through earnings and a net increase in accumulated other comprehensive income, partially offset by capital returned through common stock repurchases and dividends and higher risk-weighted assets (“RWAs”). (See “Capital” beginning on page 38.) •Our Tier 1 leverage ratio was 6.0% at Dec. 31, 2025, compared with 5.7% at Dec. 31, 2024. The increase was driven by an increase in capital, partially offset by higher average assets. (See “Capital” beginning on page 38.) 4 BNY Results of Operations (continued) Fee and other revenue [[GREPCENT_TABLE]] [["Fee and other revenue","","","","2025 vs.","2024 vs."],["(dollars in millions, unless otherwise noted)","2025","2024","2023","2024","2023"],["Investment services fees","$","10,211","","$","9,419","","$","8,843","","8","%","7","%"],["Investment management and performance fees (a)(b)","3,085","","3,139","","3,058","","(2)","","3"],["Foreign exchange revenue","706","","688","","631","","3","","9"],["Financing-related fees","231","","216","","192","","7","","13"],["Distribution and servicing fees","146","","158","","148","","(8)","","7"],["Total fee revenue","14,379","","13,620","","12,872","","6","","6"],["Investment and other revenue","757","","687","","480","","N/M","N/M"],["Total fee and other revenue","$","15,136","","$","14,307","","$","13,352","","6","%","7","%"],["Fee revenue as a percentage of total revenue","72","%","73","%","73","%"],["AUC/A at period end (in trillions) (c)","$","59.3","","$","52.1","","$","47.8","","14","%","9","%"],["AUM at period end (in billions) (d)","$","2,178","","$","2,029","","$","1,974","","7","%","3","%"]] [[/GREPCENT_TABLE]] (a)    Effective 2025, certain rebates, which were previously recorded as distribution and servicing expense, began to be reflected as a reduction of investment management fees. These amounts totaled approximately $80 million for all periods presented and impacted the variances for investment management and performance fees and related revenue subtotals in the table above. (b)    Excludes seed capital gains (losses) related to consolidated investment management funds. (c)    Consists of AUC/A primarily from the Asset Servicing line of business and, to a lesser extent, the Clearance and Collateral Management, Issuer Services, Pershing and Wealth Management lines of business. Includes the AUC/A of CIBC Mellon of $2.2 trillion at Dec. 31, 2025, $1.8 trillion at Dec. 31, 2024 and $1.7 trillion at Dec. 31, 2023. (d)    Represents assets managed in the Investment and Wealth Management business segment. N/M – Not meaningful. Fee revenue increased 6% compared with 2024, primarily reflecting higher investment services fees and foreign exchange revenue, partially offset by lower investment management and performance fees. Investment and other revenue increased $70 million in 2025 compared with 2024, primarily reflecting disposal gains and net gains on investments. Investment services fees Investment services fees increased 8% compared with 2024, primarily reflecting higher client activity and net new business, higher market values and Depositary Receipts revenue. AUC/A totaled $59.3 trillion at Dec. 31, 2025, an increase of 14% compared with Dec. 31, 2024, primarily reflecting client inflows, higher market values and the favorable impact of the weaker U.S. dollar. AUC/A consisted of 38% equity securities and 62% fixed-income securities at Dec. 31, 2025 and 37% equity securities and 63% fixed-income securities at Dec. 31, 2024. See “Securities Services business segment” and “Market and Wealth Services business segment” in “Review of business segments” for additional details. Investment management and performance fees Investment management and performance fees decreased 2% compared with 2024, primarily reflecting the mix of AUM flows and the adjustment for certain rebates (offset in noninterest expense), partially offset by higher market values and the favorable impact of a weaker U.S. dollar. Performance fees were $35 million in 2025 and $51 million in 2024. On a constant currency basis (Non-GAAP), investment management and performance fees decreased 2% compared with 2024. See “Supplemental Information – Explanation of GAAP and Non-GAAP financial measures” beginning on page 111 for the reconciliation of Non-GAAP measures. AUM was $2.2 trillion at Dec. 31, 2025, an increase of 7% compared with Dec. 31, 2024, primarily reflecting higher market values and the favorable impact of the weaker U.S. dollar, partially offset by cumulative net outflows. See “Investment and Wealth Management business segment” in “Review of business segments” for additional details regarding the drivers of investment management and performance fees, AUM and AUM flows. BNY 5 Results of Operations (continued) Foreign exchange revenue Foreign exchange revenue is primarily driven by the volume of client transactions and the spread realized on these transactions, both of which are impacted by market volatility, the impact of foreign currency hedging activities and foreign currency remeasurement gain (loss). In 2025, foreign exchange revenue increased 3% compared with 2024, primarily reflecting higher volatility and volumes. Foreign exchange revenue is primarily reported in the Securities Services business segment and, to a lesser extent, the Market and Wealth Services and Investment and Wealth Management business segments and the Other segment. Financing-related fees Financing-related fees, which are primarily reported in the Market and Wealth Services and Securities Services business segments, include capital market fees, loan commitment fees and credit-related fees. Financing-related fees increased 7% compared with 2024, primarily reflecting higher underwriting and loan fees. Distribution and servicing fees Distribution and servicing fees earned from mutual funds are primarily based on average assets in the funds and the sales of funds that we manage or administer, and are primarily reported in the Investment Management line of business. These fees, which include 12b-1 fees, fluctuate with the overall level of net sales, the relative mix of sales between share classes, the funds’ market values and money market fee waivers. Distribution and servicing fees were $146 million in 2025 compared with $158 million in 2024, driven by higher fees paid to introducing brokers. The impact of distribution and servicing fees on income in any one period is partially offset by distribution and servicing expense paid to other financial intermediaries to cover their costs for distribution and servicing of mutual funds. Distribution and servicing expense is recorded as noninterest expense on the income statement. Investment and other revenue Investment and other revenue includes income or loss from consolidated investment management funds, seed capital gains or losses, other trading revenue or loss, renewable energy investments gains, income from corporate and bank-owned life insurance contracts, other investment gains or losses, gains or losses from disposals, expense reimbursements from our CIBC Mellon joint venture, other income or loss and net securities gains or losses. The income or loss from consolidated investment management funds should be considered together with the net income or loss attributable to noncontrolling interests, which reflects the portion of the consolidated funds for which we do not have an economic interest and is reflected below net income as a separate line item on the consolidated income statement. Other trading revenue or loss primarily includes the impact of market-risk hedging activity related to our seed capital investments in investment management funds, non-foreign currency derivative and fixed income trading, and other hedging activity. Other investment gains or losses includes fair value changes of non-readily marketable strategic equity, private equity and other investments. Expense reimbursements from our CIBC Mellon joint venture relate to expenses incurred by BNY on behalf of the CIBC Mellon joint venture. Other income includes various miscellaneous revenues. 6 BNY Results of Operations (continued) The following table provides the components of investment and other revenue. [[GREPCENT_TABLE]] [["Investment and other revenue"],["(in millions)","2025","","","2024","","2023"],["Income from consolidated investment management funds","$","83","","","","$","46","","","$","30"],["Seed capital gains (a)","14","","","","20","","","29"],["Other trading revenue","279","","","","314","","","231"],["Renewable energy investment gains","55","","","","25","","","28"],["Corporate/bank-owned life insurance","165","","","","137","","","118"],["Other investment gains (b)","14","","","","67","","","47"],["Disposal gains (losses)","52","","","","\u2014","","","(6)"],["Expense reimbursements from joint venture","136","","","","118","","","117"],["Other income (loss)","39","","","","45","","","(46)"],["Net securities (losses)","(80)","","","","(85)","","","(68)"],["Total investment and other revenue","$","757","","","","$","687","","","$","480"]] [[/GREPCENT_TABLE]] (a)    Includes gains (losses) on investments in BNY funds which hedge deferred incentive awards. (b)    Includes strategic equity, private equity and other investments. Investment and other revenue was $757 million in 2025 compared with $687 million in 2024. The increase primarily reflects disposal gains and net gains on investments. Net interest income [[GREPCENT_TABLE]] [["Net interest income","","","","2025 vs.","2024 vs."],["(dollars in millions)","2025","2024","2023","2024","2023"],["Net interest income","$","4,944","","$","4,312","","$","4,345","","15%","(1)%"],["Add: Tax equivalent adjustment","1","","2","","2","","N/M","N/M"],["Net interest income on a fully taxable equivalent (\u201cFTE\u201d) basis \u2013 Non-GAAP (a)","$","4,945","","$","4,314","","$","4,347","","15%","(1)%"],["Average interest-earning assets","$","373,096","","$","353,744","","$","348,160","","5","%","2%"],["Net interest margin","1.33","%","1.22","%","1.25","%","11","bps","(3)","bps"],["Net interest margin (FTE) \u2013 Non-GAAP (a)","1.33","%","1.22","%","1.25","%","11","bps","(3)","bps"]] [[/GREPCENT_TABLE]] (a)    Net interest income (FTE) – Non-GAAP and net interest margin (FTE) – Non-GAAP include the tax equivalent adjustments on tax-exempt income, which allows for comparisons of amounts arising from both taxable and tax-exempt sources and is consistent with industry practice. The adjustment to an FTE basis has no impact on net income. N/M – Not meaningful. bps – basis points. Net interest income increased 15% compared with 2024, primarily reflecting the reinvestment of maturing investment securities at higher yields and balance sheet growth, partially offset by deposit margin compression. Net interest margin increased 11 basis points compared with 2024. The increase primarily reflects the factors mentioned above. Average interest-earning assets increased 5% compared with 2024. The increase primarily reflects higher federal funds sold and securities purchased under resale agreements and securities balances, partially offset by lower interest-bearing deposits with the Federal Reserve and other central banks. Average non-U.S. dollar deposits comprised approximately 25% of our average total deposits in 2025 and 2024. Approximately 50% of the average non-U.S. dollar deposits in 2025 and 2024 were euro-denominated. BNY 7 Results of Operations (continued) [[GREPCENT_TABLE]] [["Average balances and interest rates","2025","","2024"],["(dollars in millions)","Average balance","","Interest","","Average rate","","Average balance","","Interest","","Average rate"],["Assets"],["Interest-earning assets:"],["Interest-bearing deposits with the Federal Reserve and other central banks:"],["Domestic offices","$","61,180","","","$","2,649","","","4.33","%","","$","59,432","","","$","3,148","","","5.30","%"],["Foreign offices","33,223","","","847","","","2.55","","","40,554","","","1,467","","","3.62"],["Total interest-bearing deposits with the Federal Reserve and other central banks","94,403","","","3,496","","","3.70","","","99,986","","","4,615","","","4.62"],["Interest-bearing deposits with banks","10,929","","","325","","","2.98","","","10,991","","","434","","","3.94"],["Federal funds sold and securities purchased under resale agreements (a)","41,239","","","12,208","","","29.60","","","31,306","","","10,915","","","34.86"],["Loans:"],["Domestic offices","67,748","","","3,916","","","5.78","","","63,108","","","4,107","","","6.51"],["Foreign offices","4,848","","","230","","","4.74","","","5,033","","","287","","","5.70"],["Total loans (b)","72,596","","","4,146","","","5.71","","","68,141","","","4,394","","","6.45"],["Securities:"],["U.S. government obligations","30,367","","","1,078","","","3.55","","","27,826","","","1,022","","","3.67"],["U.S. government agency obligations","62,277","","","2,075","","","3.33","","","62,855","","","2,058","","","3.27"],["Other securities:"],["Domestic offices","15,923","","","815","","","5.12","","","17,560","","","951","","","5.42"],["Foreign offices","38,119","","","1,123","","","2.94","","","29,620","","","911","","","3.07"],["Total other securities","54,042","","","1,938","","","3.59","","","47,180","","","1,862","","","3.95"],["Total investment securities","146,686","","","5,091","","","3.47","","","137,861","","","4,942","","","3.58"],["Trading securities (primarily domestic) (c)","7,243","","","361","","","4.98","","","5,459","","","309","","","5.66"],["Total securities (c)","153,929","","","5,452","","","3.54","","","143,320","","","5,251","","","3.66"],["Total interest-earning assets (c)","$","373,096","","","$","25,627","","","6.87","%","","$","353,744","","","$","25,609","","","7.24","%"],["Noninterest-earning assets","62,795","","","","","","","59,590"],["Total assets","$","435,891","","","","","","","$","413,334"],["Liabilities and equity"],["Interest-bearing liabilities:"],["Interest-bearing deposits:"],["Domestic offices","$","149,978","","","$","4,886","","","3.26","%","","$","141,279","","","$","5,791","","","4.10","%"],["Foreign offices","98,023","","","2,174","","","2.22","","","92,926","","","2,856","","","3.07"],["Total interest-bearing deposits","248,001","","","7,060","","","2.85","","","234,205","","","8,647","","","3.69"],["Federal funds purchased and securities sold under repurchase agreements (a)","17,348","","","10,946","","","63.09","","","17,007","","","9,974","","","58.64"],["Trading liabilities","2,768","","","124","","","4.47","","","1,768","","","88","","","4.98"],["Other borrowed funds","325","","","16","","","5.04","","","439","","","18","","","4.10"],["Commercial paper","2,348","","","106","","","4.52","","","1,197","","","62","","","5.18"],["Payables to customers and broker-dealers","15,964","","","669","","","4.19","","","12,726","","","640","","","5.03"],["Long-term debt","31,919","","","1,761","","","5.52","","","31,816","","","1,866","","","5.87"],["Total interest-bearing liabilities","$","318,673","","","$","20,682","","","6.49","%","","$","299,158","","","$","21,295","","","7.12","%"],["Total noninterest-bearing deposits","50,239","","","","","","","49,521"],["Other noninterest-bearing liabilities","23,349","","","","","","","23,694"],["Total liabilities","392,261","","","","","","","372,373"],["Total The Bank of New York Mellon Corporation shareholders\u2019 equity","43,188","","","","","","","40,756"],["Noncontrolling interests","442","","","","","","","205"],["Total liabilities and equity","$","435,891","","","","","","","$","413,334"],["Net interest income (FTE) \u2013 Non-GAAP (c)(d)","","","$","4,945","","","","","","","$","4,314"],["Net interest margin (FTE) \u2013 Non-GAAP (c)(d)","","","","","1.33","%","","","","","","1.22","%"],["Less: Tax equivalent adjustment","","","1","","","","","","","2"],["Net interest income \u2013 GAAP","","","$","4,944","","","","","","","$","4,312"],["Net interest margin \u2013 GAAP","","","","","1.33","%","","","","","","1.22","%"],["Percentage of assets attributable to foreign offices","22","%","","","","","","23","%"],["Percentage of liabilities attributable to foreign offices","28","%","","","","","","28","%"]] [[/GREPCENT_TABLE]] (a)    Includes the average impact of offsetting under enforceable netting agreements of approximately $239 billion in 2025 and $176 billion in 2024. On a Non-GAAP basis, excluding the impact of offsetting, the yield on federal funds sold and securities purchased under resale agreements would have been 4.36% for 2025 and 5.28% for 2024, and the rate on federal funds purchased and securities sold under repurchase agreements would have been 4.28% for 2025 and 5.18% for 2024. We believe providing the rates excluding the impact of netting is useful to investors as it is more reflective of the actual rates earned and paid. (b)    Interest income includes fees of $4 million in 2025 and $3 million in 2024. Nonaccrual loans are included in average loans; the associated income, which was recognized on a cash basis, is included in interest income. (c)    Average rates were calculated on an FTE basis, at tax rates of approximately 21% for both 2025 and 2024. (d)    See “Net interest income” on page 7 for the reconciliation of this Non-GAAP measure. 8 BNY Results of Operations (continued) [[GREPCENT_TABLE]] [["Average balances and interest rates","2023"],["(dollars in millions)","Average balance","","Interest","","Average rate"],["Assets"],["Interest-earning assets:"],["Interest-bearing deposits with the Federal Reserve and other central banks:"],["Domestic offices","$","59,492","","","$","3,085","","","5.19","%"],["Foreign offices","44,412","","","1,456","","","3.28"],["Total interest-bearing deposits with the Federal Reserve and other central banks","103,904","","","4,541","","","4.37"],["Interest-bearing deposits with banks","13,620","","","523","","","3.84"],["Federal funds sold and securities purchased under resale agreements (a)","26,077","","","7,141","","","27.38"],["Loans:"],["Domestic offices","59,487","","","3,663","","","6.16"],["Foreign offices","4,609","","","253","","","5.49"],["Total loans (b)","64,096","","","3,916","","","6.11"],["Securities:"],["U.S. government obligations","33,434","","","1,021","","","3.05"],["U.S. government agency obligations","60,586","","","1,695","","","2.80"],["Other securities:"],["Domestic offices","17,168","","","803","","","4.68"],["Foreign offices","23,505","","","695","","","2.96"],["Total other securities","40,673","","","1,498","","","3.68"],["Total investment securities","134,693","","","4,214","","","3.13"],["Trading securities (primarily domestic) (c)","5,770","","","315","","","5.46"],["Total securities (c)","140,463","","","4,529","","","3.22"],["Total interest-earning assets (c)","$","348,160","","","$","20,650","","","5.93","%"],["Noninterest-earning assets","58,582"],["Total assets","$","406,742"],["Liabilities and equity"],["Interest-bearing liabilities:"],["Interest-bearing deposits:"],["Domestic offices","$","123,513","","","$","4,703","","","3.81","%"],["Foreign offices","88,829","","","2,421","","","2.73"],["Total interest-bearing deposits","212,342","","","7,124","","","3.35"],["Federal funds purchased and securities sold under repurchase agreements (a)","20,540","","","6,699","","","32.62"],["Trading liabilities","3,396","","","156","","","4.60"],["Other borrowed funds","1,102","","","47","","","4.27"],["Commercial paper","5","","","\u2014","","","4.81"],["Payables to customers and broker-dealers","14,449","","","566","","","3.91"],["Long-term debt","31,021","","","1,711","","","5.51"],["Total interest-bearing liabilities","$","282,855","","","$","16,303","","","5.76","%"],["Total noninterest-bearing deposits","59,227"],["Other noninterest-bearing liabilities","24,011"],["Total liabilities","366,093"],["Total The Bank of New York Mellon Corporation shareholders\u2019 equity","40,588"],["Noncontrolling interests","61"],["Total liabilities and equity","$","406,742"],["Net interest income (FTE) \u2013 Non-GAAP (c)(d)","","","$","4,347"],["Net interest margin (FTE) \u2013 Non-GAAP (c)(d)","","","","","1.25","%"],["Less: Tax equivalent adjustment","","","2"],["Net interest income \u2013 GAAP","","","$","4,345"],["Net interest margin \u2013 GAAP","","","","","1.25","%"],["Percentage of assets attributable to foreign offices","24","%"],["Percentage of liabilities attributable to foreign offices","27","%"]] [[/GREPCENT_TABLE]] (a)    Includes the average impact of offsetting under enforceable netting agreements of approximately $111 billion in 2023. On a Non-GAAP basis, excluding the impact of offsetting, the yield on federal funds sold and securities purchased under resale agreements would have been 5.22%, and the rate on federal funds purchased and securities sold under repurchase agreements would have been 5.10% for 2023. We believe providing the rates excluding the impact of netting is useful to investors as it is more reflective of the actual rates earned and paid. (b)    Interest income includes fees of $1 million in 2023. Nonaccrual loans are included in average loans; the associated income, which was recognized on a cash basis, is included in interest income. (c)    Average rates were calculated on an FTE basis, at tax rates of approximately 21% in 2023. (d)    See “Net interest income” on page 7 for the reconciliation of this Non-GAAP measure. BNY 9 Results of Operations (continued) Noninterest expense [[GREPCENT_TABLE]] [["Noninterest expense","","","","2025 vs.","2024 vs."],["(dollars in millions)","2025","2024","2023","2024","2023"],["Staff","$","7,159","","$","7,130","","$","7,095","","\u2014","%","\u2014","%"],["Software and equipment","2,147","","1,962","","1,817","","9","","8"],["Professional, legal and other purchased services","1,587","","1,503","","1,527","","6","","(2)"],["Sub-custodian and clearing","561","","498","","475","","13","","5"],["Net occupancy","551","","537","","542","","3","","(1)"],["Distribution and servicing","269","","361","","353","","(25)","","2"],["Business development","217","","188","","183","","15","","3"],["Amortization of intangible assets","45","","50","","57","","(10)","","(12)"],["Bank assessment charges","44","","36","","788","","N/M","N/M"],["Other","474","","436","","458","","9","","(5)"],["Total noninterest expense","$","13,054","","$","12,701","","$","13,295","","3","%","(4)","%"],["Full-time employees at year-end (a)","48,100","","51,800","","53,400","","(7)","%","(3)","%"]] [[/GREPCENT_TABLE]] (a)    Beginning in 2024, the number of full-time employees excludes interns. N/M – Not meaningful. Total noninterest expense increased 3% compared with 2024, primarily reflecting higher investments, employee merit increases, higher revenue-related expenses and the unfavorable impact of a weaker U.S. dollar, partially offset by efficiency savings. Excluding notable items, noninterest expense also increased 3% (Non-GAAP). See “Supervision and Regulation – FDIC Deposit Insurance” beginning on page 66 for information on the FDIC special assessment. See “Supplemental Information – Explanation of GAAP and Non-GAAP financial measures” beginning on page 111 for the reconciliation of the Non-GAAP measure. Income taxes BNY recorded an income tax provision of $1.5 billion (20.9% effective tax rate) in 2025. The income tax provision was $1.3 billion (22.3% effective tax rate) in 2024. For additional information on income taxes, see Notes 2, 11 and 25 of the Notes to Consolidated Financial Statements. Review of business segments We have an internal information system that produces performance data along product and service lines for our three principal business segments: Securities Services, Market and Wealth Services and Investment and Wealth Management, and the Other segment. Business segment accounting principles Our business segment data has been determined on an internal management basis of accounting, rather than the generally accepted accounting principles (“GAAP”) used for consolidated financial reporting. These measurement principles are designed so that reported results of the businesses will track their economic performance. Our business segments are consistent with the structure used by the President and Chief Executive Officer, our Chief Operating Decision Maker (“CODM”), to make key operating decisions and assess performance. Our CODM evaluates the business segments’ operating performance primarily based on fee and other revenue, total revenue, income before income taxes, and pre-tax operating margin. The significant expense information regularly provided to and reviewed by the CODM is total noninterest expense. The CODM considers this information when evaluating the performance of each business segment and making decisions about allocating capital and other resources to each business segment. For information on the accounting principles of our business segments, the primary products and services in each line of business, the primary types of revenue by line of business and how our business segments are presented and analyzed, see Note 23 of the Notes to Consolidated Financial Statements. 10 BNY Results of Operations (continued) Business segment results are subject to reclassification when organizational changes are made, or for refinements in revenue and expense allocation methodologies. Refinements are typically reflected on a prospective basis. In 2025, the prior periods total revenue by line of business for Investment Management and Wealth Management was revised for comparability to reflect the movement of certain fixed income investment management business from Wealth Management to Investment Management. There was no impact to total revenue reported for the Investment and Wealth Management business segment or on a consolidated basis. The results of our business segments may be influenced by client and other activities that vary by quarter. In the first quarter, staff expense typically increases, reflecting the vesting of long-term stock awards for retirement-eligible employees. The timing of our annual employee merit increases also impacts staff expense. In 2024 and 2025, the merit increase was effective in March and in 2023, the merit increase was effective in April, thus partially impacting the full-year staff expense variances. In the third quarter, volume-related fees may decline due to reduced client activity. In the fourth quarter, we typically incur higher business development and marketing expenses. In our Investment and Wealth Management business segment, performance fees are typically higher in the fourth quarter, as that quarter represents the end of the measurement period for many of the performance fee-eligible relationships. The results of our business segments may also be impacted by the translation of financial results denominated in foreign currencies to the U.S. dollar. We are primarily impacted by activities denominated in the British pound and the euro. On a consolidated basis and in our Securities Services and Market and Wealth Services business segments, we typically have more foreign currency-denominated expenses than revenues. However, our Investment and Wealth Management business segment typically has more foreign currency-denominated revenues than expenses. Overall, currency fluctuations impact the year-over-year growth rate in the Investment and Wealth Management business segment more than the Securities Services and Market and Wealth Services business segments. However, currency fluctuations, in isolation, are not expected to significantly impact net income on a consolidated basis. Fee revenue in the Investment and Wealth Management business segment, and to a lesser extent, the Securities Services and Market and Wealth Services business segments, is impacted by global market fluctuations. At Dec. 31, 2025, we estimated that a 5% change in global equity markets, spread evenly throughout the year, would impact fee revenue by less than 1% and diluted earnings per common share by $0.05 to $0.08. See Note 23 of the Notes to Consolidated Financial Statements for the consolidating schedules which show the contribution of our business segments to our overall profitability. BNY 11 Results of Operations (continued) Securities Services business segment [[GREPCENT_TABLE]] [["","","","","2025 vs.","2024 vs."],["(dollars in millions, unless otherwise noted)","2025","2024","2023","2024","2023"],["Revenue:"],["Investment services fees:"],["Asset Servicing","$","4,456","","$","4,094","","$","3,872","","9","%","6","%"],["Issuer Services","1,287","","1,163","","1,121","","11","","4"],["Total investment services fees","5,743","","5,257","","4,993","","9","","5"],["Foreign exchange revenue","596","","552","","488","","8","","13"],["Other fees (a)","266","","234","","215","","14","","9"],["Total fee revenue","6,605","","6,043","","5,696","","9","","6"],["Investment and other revenue","415","","405","","333","","N/M","N/M"],["Total fee and other revenue","7,020","","6,448","","6,029","","9","","7"],["Net interest income","2,710","","2,468","","2,569","","10","","(4)"],["Total revenue","9,730","","8,916","","8,598","","9","","4"],["Provision for credit losses","(21)","","38","","99","","N/M","N/M"],["Noninterest expense (excluding amortization of intangible assets)","6,505","","6,286","","6,327","","3","","(1)"],["Amortization of intangible assets","27","","28","","31","","(4)","","(10)"],["Total noninterest expense","6,532","","6,314","","6,358","","3","","(1)"],["Income before income taxes","$","3,219","","$","2,564","","$","2,141","","26","%","20","%"],["Pre-tax operating margin","33","%","29","%","25","%"],["Securities lending revenue (b)","$","239","","$","191","","$","189","","25","%","1","%"],["Total revenue by line of business:"],["Asset Servicing","$","7,516","","$","6,872","","$","6,612","","9","%","4","%"],["Issuer Services","2,214","","2,044","","1,986","","8","","3"],["Total revenue by line of business","$","9,730","","$","8,916","","$","8,598","","9","%","4","%"],["Selected average balances:"],["Average loans","$","11,204","","$","11,235","","$","11,207","","\u2014","%","\u2014","%"],["Average deposits","$","184,433","","$","178,643","","$","168,411","","3","%","6","%"],["Selected metrics:"],["AUC/A at period end (in trillions) (c)","$","43.0","","$","37.7","","$","34.2","","14","%","10","%"],["Market value of securities on loan at period end (in billions) (d)","$","604","","$","488","","$","450","","24","%","8","%"],["Issuer Services:"],["Total debt serviced at period end (in trillions)","$","14.8","","$","14.1","","$","14.0","","5","%","1","%"],["Number of Depositary Receipts programs at period end","1,614","","1,576","","1,645","","2","%","(4)","%"]] [[/GREPCENT_TABLE]] (a)    Other fees primarily include financing-related fees. (b)    Included in investment services fees reported in the Asset Servicing line of business. (c)    Consists of AUC/A primarily from the Asset Servicing line of business and, to a lesser extent, the Issuer Services line of business. Includes the AUC/A of CIBC Mellon of $2.2 trillion at Dec. 31, 2025, $1.8 trillion at Dec. 31, 2024 and $1.7 trillion at Dec. 31, 2023. (d)    Represents the total amount of securities on loan in our agency securities lending program. Excludes securities for which BNY acts as agent on behalf of CIBC Mellon clients, which totaled $74 billion at Dec. 31, 2025, $60 billion at Dec. 31, 2024 and $63 billion at Dec. 31, 2023. N/M – Not meaningful. 12 BNY Results of Operations (continued) Business segment description The Securities Services business segment consists of two distinct lines of business, Asset Servicing and Issuer Services, which provide business solutions across the transaction lifecycle to our global asset owner, asset manager and corporate clients. We are one of the leading global investment services providers with $43.0 trillion of AUC/A at Dec. 31, 2025. For information on the drivers of the Securities Services fee revenue, see Note 9 of the Notes to Consolidated Financial Statements. The Asset Servicing business provides a comprehensive suite of solutions. We are one of the largest global custody, fund administrator and front-to-back outsourcing service providers. We offer services for the safekeeping of assets in capital markets globally as well as fund accounting services, exchange-traded funds servicing, transfer agency, trust and depository, front-to-back capabilities, data and analytics solutions and digital asset custody and administration services for our clients. We deliver foreign exchange, and securities lending and financing solutions, on both an agency and principal basis. Our agency securities lending program is one of the largest lenders of U.S. and non-U.S. securities, servicing a lendable asset pool of approximately $6.1 trillion in 35 markets. Our market-leading liquidity services portal enables cash investments for institutional clients and includes fund research and analytics. The Issuer Services business includes Corporate Trust and Depositary Receipts. Our Corporate Trust business delivers a full range of issuer and related investor services, including trustee, paying agency, fiduciary, escrow and other financial services. We are a leading provider to the debt capital markets, providing customized and market-driven solutions to investors, bondholders and lenders. Our Depositary Receipts business drives global investing by providing servicing and value- added solutions that enable, facilitate and enhance cross-border trading, clearing, settlement and ownership. We are one of the largest providers of depositary receipts services in the world, partnering with leading companies from more than 50 countries. Review of financial results AUC/A of $43.0 trillion increased 14% compared with Dec. 31, 2024, primarily reflecting higher market values, client inflows and the favorable impact of a weaker U.S. dollar. Total revenue of $9.7 billion increased 9% compared with 2024. The drivers of total revenue by line of business are indicated below. Asset Servicing revenue of $7.5 billion increased 9% compared with 2024, primarily reflecting higher net interest income, client activity, market values, net new business and a disposal gain, partially offset by an investment loss. Issuer Services revenue of $2.2 billion increased 8% compared with 2024, primarily reflecting higher Depositary Receipts revenue and a disposal gain. Market and regulatory trends are driving investable assets toward lower fee asset management products at reduced margins for our clients. These dynamics are also negatively impacting our investment services fees. However, at the same time, these trends are providing additional outsourcing opportunities as clients and other market participants seek to comply with regulations and reduce their operating costs. Noninterest expense of $6.5 billion increased 3% compared with 2024, primarily reflecting higher investments, revenue-related expenses, employee merit increases and the unfavorable impact of the weaker U.S. dollar, partially offset by efficiency savings. BNY 13 Results of Operations (continued) Market and Wealth Services business segment [[GREPCENT_TABLE]] [["","","","","2025 vs.","2024 vs."],["(dollars in millions, unless otherwise noted)","2025","2024","2023","2024","2023"],["Revenue:"],["Investment services fees:"],["Pershing","$","2,029","","$","1,947","","$","1,885","","4","%","3","%"],["Payments and Trade (a)","844","","792","","717","","7","","10"],["Clearance and Collateral Management","1,562","","1,385","","1,212","","13","","14"],["Total investment services fees","4,435","","4,124","","3,814","","8","","8"],["Foreign exchange revenue","118","","97","","81","","22","","20"],["Other fees (b)","263","","235","","202","","12","","16"],["Total fee revenue","4,816","","4,456","","4,097","","8","","9"],["Investment and other revenue","88","","79","","63","","N/M","N/M"],["Total fee and other revenue","4,904","","4,535","","4,160","","8","","9"],["Net interest income","2,096","","1,729","","1,710","","21","","1"],["Total revenue","7,000","","6,264","","5,870","","12","","7"],["Provision for credit losses","(12)","","19","","41","","N/M","N/M"],["Noninterest expense (excluding amortization of intangible assets)","3,585","","3,349","","3,199","","7","","5"],["Amortization of intangible assets","3","","4","","6","","(25)","","(33)"],["Total noninterest expense","3,588","","3,353","","3,205","","7","","5"],["Income before income taxes","$","3,424","","$","2,892","","$","2,624","","18","%","10","%"],["Pre-tax operating margin","49","%","46","%","45","%"],["Total revenue by line of business:"],["Pershing","$","2,928","","$","2,687","","$","2,616","","9","%","3","%"],["Payments and Trade (a)","2,001","","1,737","","1,637","","15","","6"],["Clearance and Collateral Management","2,071","","1,840","","1,617","","13","","14"],["Total revenue by line of business","$","7,000","","$","6,264","","$","5,870","","12","%","7","%"],["Selected average balances:"],["Average loans","$","45,804","","$","41,533","","$","37,502","","10","%","11","%"],["Average deposits","$","96,958","","$","90,185","","$","85,785","","8","%","5","%"],["Selected metrics:"],["AUC/A at period end (in trillions) (c)","$","15.9","","$","14.1","","$","13.3","","13","%","6","%"],["Pershing:"],["AUC/A at period end (in trillions)","$","3.0","","$","2.7","","$","2.5","","11","%","8","%"],["Net new assets (U.S. platform) (in billions) (d)","$","55","","$","(6)","","$","22","","N/M","N/M"],["Daily average revenue trades (\u201cDARTs\u201d) (U.S. platform) (in thousands)","296","","269","","234","","10","%","15","%"],["Average active clearing accounts (in thousands)","8,421","","8,098","","7,946","","4","%","2","%"],["Payments and Trade: (a)"],["Average daily U.S. dollar payment volumes","248,808","","242,997","","236,696","","2","%","3","%"],["Clearance and Collateral Management:"],["Average collateral balances (in billions)","$","7,091","","$","6,217","","$","6,343","","14","%","(2)","%"]] [[/GREPCENT_TABLE]] (a)    Formerly Treasury Services. (b)    Other fees primarily include financing-related fees. (c)    Consists of AUC/A from the Clearance and Collateral Management and Pershing businesses. (d)    Net new assets represent net flows of assets (e.g., net cash deposits and net securities transfers, including dividends and interest) in customer accounts in Pershing LLC, a U.S. broker-dealer. N/M – Not meaningful. 14 BNY Results of Operations (continued) Business segment description The Market and Wealth Services business segment consists of three distinct lines of business, Pershing, Payments and Trade and Clearance and Collateral Management, which provide business services and technology solutions to entities including financial institutions, corporations, foundations and endowments, public funds and government agencies. For information on the drivers of the Market and Wealth Services fee revenue, see Note 9 of the Notes to Consolidated Financial Statements. Pershing provides execution, clearing, custody and technology solutions, delivering operational support to broker-dealers, wealth managers and registered investment advisors (“RIAs”) globally. Our Payments and Trade business is a leading provider of global payments, liquidity management and trade finance services for financial institutions, corporations and the public sector. Our Clearance and Collateral Management business clears and settles equity and fixed-income transactions globally and serves as custodian for tri-party repo collateral worldwide. We are the primary provider of U.S. government securities clearance and a provider of non-U.S. government securities clearance. Our collateral services include collateral management, administration and segregation. We offer innovative solutions and industry expertise that help financial institutions and institutional investors with their financing, risk and balance sheet opportunities. Review of financial results AUC/A of $15.9 trillion increased 13% compared with Dec. 31, 2024, primarily reflecting client inflows and higher market values. Total revenue of $7.0 billion increased 12% compared with 2024. The drivers of total revenue by line of business are indicated below. Pershing revenue of $2.9 billion increased 9% compared with 2024, primarily reflecting higher net interest income, market values and client activity. Payments and Trade, formerly Treasury Services, revenue of $2.0 billion increased 15% compared with 2024, primarily reflecting higher net interest income and net new business, partially offset by an investment loss. Clearance and Collateral Management revenue of $2.1 billion increased 13% compared with 2024, primarily reflecting higher collateral management balances, clearance volumes and net interest income. Noninterest expense of $3.6 billion increased 7% compared with 2024, primarily reflecting higher investments, employee merit increases, revenue-related expenses, and higher litigation reserves and severance expense, partially offset by efficiency savings. BNY 15 Results of Operations (continued) Investment and Wealth Management business segment [[GREPCENT_TABLE]] [["","","","","","","","2025 vs.","","2024 vs."],["(dollars in millions)","2025","","2024","","2023","","2024","","2023"],["Revenue:"],["Investment management fees (a)","$","3,052","","","$","3,093","","","$","2,981","","","(1)","%","","4","%"],["Performance fees","35","","","51","","","81","","","N/M","","N/M"],["Investment management and performance fees (b)","3,087","","","3,144","","","3,062","","","(2)","","","3"],["Distribution and servicing fees","275","","","275","","","241","","","\u2014","","","14"],["Other fees (c)","(313)","","","(256)","","","(214)","","","N/M","","N/M"],["Total fee revenue","3,049","","","3,163","","","3,089","","","(4)","","","2"],["Investment and other revenue (d)","35","","","50","","","(102)","","","N/M","","N/M"],["Total fee and other revenue (d)","3,084","","","3,213","","","2,987","","","(4)","","","8"],["Net interest income","174","","","176","","","168","","","(1)","","","5"],["Total revenue","3,258","","","3,389","","","3,155","","","(4)","","","7"],["Provision for credit losses","5","","","4","","","(4)","","","N/M","","N/M"],["Noninterest expense (excluding amortization of intangible assets) (a)","2,695","","","2,762","","","2,756","","","(2)","","","\u2014"],["Amortization of intangible assets","15","","","18","","","20","","","(17)","","","(10)"],["Total noninterest expense","2,710","","","2,780","","","2,776","","","(3)","","","\u2014"],["Income before income taxes","$","543","","","$","605","","","$","383","","","(10)","%","","58","%"],["Pre-tax operating margin","17","%","","18","%","","12","%"],["Total revenue by line of business:"],["Investment Management (e)","$","2,197","","","$","2,330","","","$","2,148","","","(6)","%","","8","%"],["Wealth Management (e)","1,061","","","1,059","","","1,007","","","\u2014","","","5"],["Total revenue by line of business","$","3,258","","","$","3,389","","","$","3,155","","","(4)","%","","7","%"],["Selected average balances:"],["Average loans","$","13,902","","","$","13,610","","","$","13,718","","","2","%","","(1)","%"],["Average deposits","$","9,445","","","$","10,589","","","$","14,280","","","(11)","%","","(26)","%"]] [[/GREPCENT_TABLE]] (a)    Effective 2025, certain rebates, which were previously recorded as distribution and servicing expense, began to be reflected as a reduction of investment management fees. These amounts totaled approximately $80 million for all periods presented and impacted the variance for investment management fees and related revenue subtotals, noninterest expense and Investment Management total revenue in the table above. (b)    On a constant currency basis, investment management and performance fees decreased 3% (Non-GAAP) compared with 2024. See “Supplemental Information – Explanation of GAAP and Non-GAAP financial measures” beginning on page 111 for the reconciliation of this Non-GAAP measure. (c)    Other fees primarily include investment services fees. (d)    Investment and other revenue and total fee and other revenue are net of income (loss) attributable to noncontrolling interests related to consolidated investment management funds. (e)    In 2025, prior periods total revenue by line of business for Investment Management and Wealth Management was revised for comparability to reflect the movement of certain fixed income investment management business from Wealth Management to Investment Management. There was no impact to total revenue reported for the Investment and Wealth Management business segment or on a consolidated basis. N/M – Not meaningful. 16 BNY Results of Operations (continued) [[GREPCENT_TABLE]] [["AUM trends"],["(in billions)","2025","2024","2023"],["AUM by product type: (a)"],["Equity","$","179","","$","162","","$","145"],["Fixed income","262","","221","","205"],["Index","517","","491","","459"],["Liability-driven investments","539","","548","","605"],["Multi-asset and alternative investments","186","","171","","170"],["Cash","495","","436","","390"],["Total AUM","$","2,178","","$","2,029","","$","1,974"],["Changes in AUM (a):"],["Beginning balance of AUM","$","2,029","","$","1,974","","$","1,836"],["Net inflows (outflows):"],["Long-term strategies:"],["Equity","(18)","","(15)","","(12)"],["Fixed income","19","","18","","(4)"],["Liability-driven investments","(37)","","2","","12"],["Multi-asset and alternative investments","(8)","","(15)","","(9)"],["Total long-term active strategies (outflows)","(44)","","(10)","","(13)"],["Index","(49)","","(42)","","(12)"],["Total long-term strategies (outflows)","(93)","","(52)","","(25)"],["Short-term strategies:"],["Cash","56","","45","","5"],["Total net (outflows)","(37)","","(7)","","(20)"],["Net market impact","115","","69","","121"],["Net currency impact","56","","(25)","","37"],["Other (b)","15","","18","","\u2014"],["Ending balance of AUM","$","2,178","","$","2,029","","$","1,974"],["Wealth Management client assets (c)","$","350","","$","327","","$","312"]] [[/GREPCENT_TABLE]] (a)    Represents assets managed in the Investment and Wealth Management business segment. (b)    Activity in 2025 reflects a change in methodology to include assets under advisement. Activity in 2024 reflects the realignment of similar products and services within our lines of business. (c)    Includes AUM and AUC/A in the Wealth Management line of business. Business segment description The Investment and Wealth Management business segment consists of Investment Management and Wealth Management lines of business, and has a combined AUM of $2.2 trillion as of Dec. 31, 2025. Our Investment Management business is a multi-asset portfolio solutions provider offering products and investments for institutional and retail clients globally. This includes a global distribution platform and seven specialized investment firms: BNY Investments Dreyfus, a liquidity solutions provider; BNY Investments Mellon, an index provider; Insight Investment, our fixed income franchise; BNY Investments Newton, an equity and multi-asset manager; Walter Scott, a specialized equity manager; and Brazilian equity manager ARX. BNY also owns a noncontrolling interest in Siguler Gulf, a multi-strategy private equity investment firm. Each highly experienced investment team has its own proprietary investment process and approach. Investment Management also delivers integrated portfolio solutions, including models and Outsourced Chief Investment Officer services. Our multi-asset investment expertise also powers our sub-advisory services for ETFs, separately managed accounts, digital assets and model portfolios. Wealth Management provides investment management, custody, wealth and estate planning, private banking services, investment servicing and information management. Wealth Management has $350 billion in client assets as of Dec. 31, 2025, and more than 30 offices in the U.S. and internationally. Wealth Management clients include individuals, families and institutions, such as family offices, charitable gift programs, endowments and foundations. We work with clients to build, manage and sustain wealth across generations and market cycles. Wealth Management differentiates itself with a comprehensive wealth management framework called Active Wealth that seeks to empower clients to build and sustain long-term wealth. The results of the Investment and Wealth Management business segment are driven by a blend of daily, monthly and quarterly AUM by product type. The overall level of AUM for a given period is determined by: •the beginning level of AUM; •the net flows of new assets during the period resulting from new business wins and existing client inflows, reduced by the loss of clients and existing client outflows; and •the impact of market price appreciation or depreciation, foreign exchange rates and investment firm acquisitions or divestitures. The mix of AUM is a result of the historical growth rates of equity and fixed income markets and the cumulative net flows of our investment firms as a result of client asset allocation decisions. Actively BNY 17 Results of Operations (continued) managed equity, multi-asset and alternative assets typically generate higher percentage fees than fixed-income and liability-driven investments and cash. Also, actively managed assets typically generate higher management fees than indexed or passively managed assets of the same type. Market and regulatory trends have resulted in increased demand for lower fee asset management products and for performance-based fees. Investment management fees are dependent on the overall level and mix of AUM and the management fees expressed in basis points (one-hundredth of one percent) charged for managing those assets. Management fees are typically subject to fee schedules based on the overall level of assets managed for a single client or by individual asset class and style. This is most common for institutional clients where we typically manage substantial assets for individual accounts. Performance fees are generally calculated as a percentage of a portfolio’s performance in excess of a benchmark index or a peer group’s performance. A key driver of growth in investment management and performance fees is the amount of net new AUM flows. Overall market conditions are also key drivers, with a significant long-term economic driver being growth of global financial assets. Net interest income is determined by loan and deposit volumes and the interest rate spread between customer rates and internal funds transfer rates on loans and deposits. Expenses in the Investment and Wealth Management business segment are mainly driven by staff and distribution and servicing expenses. Review of financial results AUM of $2.2 trillion increased 7% compared with Dec. 31, 2024, primarily reflecting higher market values and the favorable impact of a weaker U.S. dollar, partially offset by cumulative net outflows. Net long-term strategy outflows were $93 billion in 2025, primarily driven by outflows of index, liability-driven investments and equity investments, partially offset by inflows of fixed income investments. Short-term strategy inflows were $56 billion in 2025. Total revenue of $3.3 billion decreased 4% compared with 2024. The drivers of total revenue by line of business are indicated below. Investment Management revenue of $2.2 billion decreased 6% compared with 2024, primarily reflecting the mix of AUM flows and the adjustment for certain rebates (offset in noninterest expense) (refer to note (a) on page 16), partially offset by higher market values and the favorable impact of the weaker U.S. dollar. Wealth Management revenue of $1.1 billion was flat compared with 2024, primarily reflecting higher market values, partially offset by changes in product mix. Revenue generated in the Investment and Wealth Management business segment included 28% from non-U.S. sources in 2025, compared with 30% in 2024. Noninterest expense of $2.7 billion decreased 3% compared with 2024, primarily reflecting lower revenue-related expenses (including the adjustment for certain rebates) (refer to note (a) on page 16) and efficiency savings, partially offset by higher investments, employee merit increases and the unfavorable impact of the weaker U.S. dollar. 18 BNY Results of Operations (continued) Other segment [[GREPCENT_TABLE]] [["(in millions)","2025","2024","2023"],["Fee revenue","$","(91)","","$","(42)","","$","(10)"],["Investment and other revenue","185","","140","","184"],["Total fee and other revenue","94","","98","","174"],["Net interest expense","(36)","","(61)","","(102)"],["Total revenue","58","","37","","72"],["Provision for credit losses","(4)","","9","","(17)"],["Noninterest expense","224","","254","","956"],["(Loss) before income taxes","$","(162)","","$","(226)","","$","(867)"],["Average loans","$","1,686","","$","1,763","","$","1,669"]] [[/GREPCENT_TABLE]] Segment description The Other segment primarily includes: •corporate treasury activities, including our securities portfolio; •tax credit investments and other corporate investments; •corporate and bank-owned life insurance; •derivatives and other trading activity; and •certain business exits. Revenue primarily reflects: •net interest income (expense) and derivatives and other corporate treasury activities; •investment and other revenue from corporate and bank-owned life insurance, gains (losses) associated with investment securities and other assets; •other revenue from certain business exits; and •fee revenue from the elimination of the results of certain services provided between segments, which are also provided to third parties. Expenses include: •direct expenses supporting investing and funding activities; and •expenses not directly attributable to Securities Services, Market and Wealth Services and Investment and Wealth Management operations. Review of financial results Loss before taxes was $162 million in 2025 compared with $226 million in 2024. Total revenue increased $21 million compared with 2024, primarily reflecting other investment gains. Noninterest expense decreased $30 million compared with 2024, primarily driven by lower severance expense and litigation reserves. International operations Our primary international activities consist of asset servicing in our Securities Services business segment, global payment services in our Market and Wealth Services business segment and investment management in our Investment and Wealth Management business segment. Our clients include central banks and sovereigns, financial institutions, asset managers, insurance companies, corporations, local authorities and high-net-worth individuals and family offices. Through our global network of offices, we have developed a deep understanding of local requirements and cultural needs, and we pride ourselves on providing dedicated service through our multilingual sales, marketing and client service teams. At Dec. 31, 2025, approximately 60% of our total employees (full-time and part-time employees) were based outside the U.S., with approximately 10,100 employees in Europe, the Middle East and Africa, approximately 18,000 employees in the Asia-Pacific region and approximately 700 employees in other global locations, primarily Brazil. We are a leading global asset manager. Our international operations managed 46% of BNY’s AUM at Dec. 31, 2025 and 47% at Dec. 31, 2024. We offer a full range of tailored solutions for investment companies, financial institutions and institutional investors across most European markets. BNY 19 Results of Operations (continued) We are a provider of non-U.S. government securities, fixed income and equities clearance, settling securities transactions directly in European markets, and using a high-quality and established network of local agents in non-European markets. We have extensive experience providing trade and cash services to financial institutions and central banks outside of the U.S. In addition, we offer a broad range of servicing and fiduciary products to financial institutions, corporations and central banks. In emerging markets, we lead with custody, global payments and issuer services, introducing other products as the markets mature. For more established markets, our focus is on global investment services. We are also a full-service global provider of foreign exchange services, actively trading in over 100 of the world’s currencies. We serve clients from trading desks located in Europe, Asia and North America. Our financial results, as well as our levels of AUC/A and AUM, are impacted by translation from foreign currencies to the U.S. dollar. We are primarily impacted by activities denominated in the British pound and the euro. If the U.S. dollar depreciates against these currencies, the translation impact is a higher level of fee revenue, net interest income, noninterest expense and AUC/A and AUM. Conversely, if the U.S. dollar appreciates, the translated levels of fee revenue, net interest income, noninterest expense and AUC/A and AUM will be lower. International clients accounted for 35% of revenues in 2025 and 35% in 2024. Net income from international operations was $2.4 billion in 2025, compared with $2.3 billion in 2024. For additional information regarding our international operations, including certain key subjective assumptions used in determining the results, see Note 24 of the Notes to Consolidated Financial Statements. 20 BNY Results of Operations (continued) Country risk exposure The following table presents BNY’s top 10 exposures by country (excluding the U.S.) as of Dec. 31, 2025, as well as certain countries with higher-risk profiles. The exposure is presented on an internal risk management basis and has not been reduced by the allowance for credit losses. We monitor our exposure to these and other countries as part of our internal country risk management process. The country risk exposure below reflects the Company’s risk to an immediate default of the counterparty or obligor based on the country of residence of the entity which incurs the liability. If there is credit risk mitigation, the country of residence of the entity providing the risk mitigation is the country of risk. The country of risk for securities is generally based on the domicile of the issuer of the security. The country risk exposure below does not reflect exposure that might arise from certain commitments and contingent liabilities set forth in Note 21 of the Notes to Financial Statements. [[GREPCENT_TABLE]] [["Country risk exposure at Dec. 31, 2025","Interest-bearing deposits","","","","","","","","Total exposure"],["(in billions)","Central banks","Banks","","Lending (a)","","Securities (b)","","Other (c)"],["Top 10 country exposure:"],["United Kingdom (\u201cUK\u201d)","$","9.5","","$","0.3","","","$","1.2","","","$","7.1","","","$","2.4","","","$","20.5"],["Germany","14.4","","0.3","","","0.7","","","3.6","","","0.3","","","19.3"],["Canada","\u2014","","0.9","","","0.1","","","4.1","","","1.5","","","6.6"],["Netherlands","1.3","","\u2014","","","0.4","","","3.6","","","0.2","","","5.5"],["Luxembourg","0.2","","0.3","","","1.3","","","0.1","","","1.8","","","3.7"],["France","\u2014","","0.1","","","0.1","","","3.0","","","0.3","","","3.5"],["Belgium","1.5","","0.6","","","0.1","","","1.2","","","0.1","","","3.5"],["South Korea","0.2","","0.1","","","2.1","","","0.2","","","0.8","","","3.4"],["Australia","\u2014","","1.3","","","0.3","","","0.9","","","0.6","","","3.1"],["Japan","1.5","","0.7","","","\u2014","","","0.5","","","0.3","","","3.0"],["Total Top 10 country exposure","$","28.6","","$","4.6","","","$","6.3","","","$","24.3","","","$","8.3","","","$","72.1","","(d)"],["Select country exposure:"],["Brazil","$","\u2014","","$","0.1","","","$","1.2","","","$","0.1","","","$","0.1","","","$","1.5"],["Russia","\u2014","","1.3","","(e)","\u2014","","","\u2014","","","\u2014","","","1.3"]] [[/GREPCENT_TABLE]] (a)    Lending includes loans, acceptances, issued letters of credit, net of participations, and lending-related commitments. (b)    Securities include both the available-for-sale and held-to-maturity portfolios. (c)    Other exposure includes over-the-counter (“OTC”) derivative and securities financing transactions, net of collateral. (d)    The top 10 country exposure comprises approximately 65% of our total non-U.S. exposure. (e)    Represents cash balances with exposure to Russia. We have exposure to certain countries with higher risk profiles. The country risk exposure to Brazil is primarily short-term trade finance loans extended to large financial institutions. We also have operations in Brazil providing investment services and investment management services. The war in Ukraine has increased our focus on Russia. The country risk exposure to Russia consists of cash balances related to our Securities Services businesses and may increase in the future to the extent cash is allocated for the benefit of our clients that is subject to distribution restrictions. BNY has ceased new banking business in Russia and suspended investment management purchases of Russian securities. Russian securities included in our AUC/A and AUM at Dec. 31, 2025, continue to be insignificant as a percentage of the total AUC/A and AUM, respectively. We will continue to work with multinational clients that depend on our custody and recordkeeping services to manage their exposures. Critical accounting estimates Our significant accounting policies are described in Note 1 of the Notes to Consolidated Financial Statements. Certain of these policies include critical accounting estimates which require management to make subjective or complex judgments about the effect of matters that are inherently uncertain and may change in subsequent periods. Our critical accounting estimates are those related to the BNY 21 Results of Operations (continued) allowance for credit losses, goodwill and other intangibles and litigation and regulatory contingencies. Management has discussed the development and selection of the critical accounting estimates with the Company’s Audit Committee. Allowance for credit losses The allowance for credit losses covers financial assets subject to credit losses and measured at amortized cost, including loans and lending-related commitments, held-to-maturity securities, certain securities financing transactions and deposits with banks. The allowance for credit losses is intended to adjust the carrying value of these assets by an estimated amount of credit losses that we expect to incur over the life of the asset. Similarly, the allowance for credit losses on lending-related commitments and other off-balance sheet financial instruments is meant to capture the credit losses that we expect to recognize in these portfolios as of the balance sheet date. A quantitative methodology and qualitative framework is used to estimate the allowance for credit losses. The quantitative component of our estimate uses models and methodologies that categorize financial assets based on product type, collateral type, and other credit trends and risk characteristics, including relevant information about past events, current conditions and reasonable and supportable forecasts of future economic conditions that affect the collectability of the recorded amounts. For the quantitative component, we segment portfolios into various major components including commercial, commercial real estate, financial institutions, residential mortgages and other loans. The segmentation of our debt securities portfolios is by major asset class and is influenced by whether the security is structured or non-structured (i.e., direct obligation), as well as the issuer type. The components of the credit loss calculation for each major portfolio or asset class include a probability of default, loss given default and exposure at default, as applicable, and their values depend on the forecast behavior of variables in the macroeconomic environment. We utilize a multi-scenario macroeconomic forecast which includes a weighting of three scenarios: a baseline and upside and downside scenarios and allows us to develop our estimate using a wide span of economic variables. Our baseline scenario reflects a view on likely performance of each global region and the other two scenarios are designed relative to the baseline scenario. This approach incorporates a reasonable and supportable forecast period spanning the life of the asset, and includes both an initial estimated economic outlook component as well as a reversion component for each economic input variable. The length of each of the two components depends on the underlying financial instrument, scenario, and underlying economic input variable. In general, the initial economic outlook period for each economic input variable under each scenario ranges between several months and two years. The speed at which the scenario-specific forecasts revert to long-term historical mean is based on observed historical patterns of mean reversion at the economic variable input level that are reflected in our model parameter estimates. Certain macroeconomic variables such as unemployment or home prices take longer to revert after a contraction, though specific recovery times are scenario-specific. Reversion will usually take longer the further away the scenario-specific forecast is from the historical mean. On a quarterly basis, and within a developed governance structure, we update these scenarios for current economic conditions and may adjust the scenario weighting based on our economic outlook. The Company uses judgment to assess these economic conditions and loss data in determining the best estimate of the allowance for credit losses and these estimates are subject to periodic refinement based on changes to underlying external or Company-specific historical data. In the quantitative component of our estimate, we measure expected credit losses using an individual evaluation method if the risk characteristics of the asset is no longer consistent with the portfolio or class of asset. For these assets, we do not employ the macroeconomic model calculation but consider factors such as payment status, collateral value, the obligor’s financial condition, guarantor support, the probability of collecting scheduled principal and interest payments when due, and recovery expectations if they can be reasonably estimated. For loans, we measure the expected credit loss as the difference between the amortized cost basis of the loan and the present value of the expected future cash flows from the borrower which is generally discounted at the loan’s effective interest rate, or the fair value of the collateral, if the loan is collateral-dependent. We generally individually evaluate 22 BNY Results of Operations (continued) nonperforming loans as well as loans that have been modified given the risk characteristics of such loans. Available-for-sale debt securities are recorded at fair value. When an available-for-sale debt security is in an unrealized loss position, we employ a methodology to identify and estimate the credit loss portion of the unrealized loss position. The measurement of expected credit losses is performed at the security level and is based on our best single estimate of cash flows, on a discounted basis; however, we do not specifically employ the macroeconomic forecasting models and scenarios summarized above. The qualitative component of our estimate for the allowance for credit losses is intended to capture expected losses that may not have been fully captured in the quantitative component. Through an established governance structure, management determines the qualitative allowance each period based on an evaluation of various internal and environmental factors that include: scenario weighting and sensitivity risk, credit concentration risk, economic conditions and other considerations. We have made and may continue to make adjustments for idiosyncratic risks. To the extent actual results differ from forecasts or management’s judgment, the allowance for credit losses may be greater or less than future charge-offs and recoveries. Our allowance for credit losses is sensitive to a number of inputs, most notably the macroeconomic forecast assumptions that are incorporated into our estimate of credit losses through the expected life of the loan portfolio, as well as credit ratings assigned to each borrower. As the macroeconomic environment and related forecasts change, the allowance for credit losses may change materially. The following sensitivity analyses do not represent management’s expectations of the deterioration of our portfolios or the economic environment, but are provided as hypothetical scenarios to assess the sensitivity of the allowance for credit losses to changes in key inputs. If commercial real estate property values were increased 10% and all other credits were rated one grade better, the quantitative allowance would have decreased by $40 million, and if commercial real estate property values were decreased 10% and all other credits were rated one grade worse, the quantitative allowance would have increased by $74 million. Our multi-scenario macroeconomic forecast used in determining the Dec. 31, 2025 allowance for credit losses consisted of three scenarios. The baseline scenario reflects gross domestic product (“GDP”) growth through mid-2026 before moderating for the remainder of 2026, slightly increasing unemployment through 2026 and stable commercial real estate prices through 2026. The upside scenario reflects higher GDP growth through mid-2026 before moderating for the remainder of 2026, declining unemployment through mid-2026 before stabilizing for the remainder of 2026 and slightly increasing commercial real estate prices through 2026 compared with the baseline. The downside scenario contemplates negative GDP growth through mid-2026, rapidly increasing unemployment through 2026 and sharply lower commercial real estate prices through 2026 compared with the baseline. At Dec. 31, 2025, we placed the largest weighting on our baseline scenario, followed by the downside scenario, with the remaining weighting placed on the upside scenario. From a sensitivity perspective, at Dec. 31, 2025, if we had applied 100% weighting to the downside scenario, the quantitative allowance for credit losses would have been approximately $99 million higher. See Notes 1 and 4 of the Notes to Consolidated Financial Statements for additional information regarding the allowance for credit losses. Goodwill and other intangibles We initially record all assets and liabilities acquired in purchase acquisitions, including goodwill, indefinite-lived intangibles and other intangibles, in accordance with Accounting Standards Codification (“ASC”) 805, Business Combinations. Goodwill, indefinite-lived intangibles and other intangibles are subsequently accounted for in accordance with ASC 350, Intangibles – Goodwill and Other. The initial measurement of goodwill and intangibles requires judgment concerning estimates of the fair value of the acquired assets and liabilities. Goodwill ($16.8 billion at Dec. 31, 2025) and indefinite-lived intangible assets ($2.6 billion at Dec. 31, 2025) are not amortized but are subject to tests for impairment annually or more often if events or circumstances indicate it is more likely than not they may be impaired. Other intangible assets are amortized over their estimated useful lives and are subject to impairment if events or circumstances indicate a possible inability to realize the carrying value. BNY 23 Results of Operations (continued) Goodwill BNY’s business segments include seven reporting units for which goodwill impairment testing is performed on an annual basis. An interim goodwill impairment test is performed when events or circumstances occur that may indicate that it is more likely than not that the fair value of any reporting unit may be less than its carrying value. The goodwill impairment test compares the estimated fair value of the reporting unit with its carrying amount, including goodwill. If the estimated fair value of the reporting unit exceeds its carrying amount, goodwill of the reporting unit is considered not impaired. However, if the carrying amount of the reporting unit were to exceed its estimated fair value, an impairment loss would be recorded for the difference. In each quarter of 2025, we completed an interim goodwill impairment test of the Investment Management reporting unit, which had $6.3 billion of allocated goodwill as of Dec. 31, 2025. In all cases, we determined the fair value of the Investment Management reporting unit exceeded its carrying value and no goodwill impairment was recorded. For the Dec. 31, 2025 interim goodwill impairment test, the fair value of the Investment Management reporting unit exceeded its carrying value by approximately 10%. We determined the fair value of the Investment Management reporting unit using an income approach based on management’s projections as of Dec. 31, 2025. The discount rate applied to these cash flows was 10%. As of Dec. 31, 2025, if the discount rate applied to the estimated cash flows was increased or decreased by 25 basis points, the fair value of the Investment Management reporting unit would decrease or increase by approximately 4%, respectively. Similarly, if the long-term growth rate was increased or decreased by 10 basis points, the fair value of the Investment Management reporting unit would increase or decrease by approximately 1%, respectively. In the second quarter of 2025, we performed our annual goodwill impairment test on the remaining six reporting units using an income approach to estimate the fair values of each reporting unit. Estimated cash flows used in the income approach were based on management’s projections as of April 1, 2025. The discount rate applied to these cash flows was 10%. As a result of the annual goodwill impairment test, no goodwill impairment was recognized. The fair values of the Company’s remaining six reporting units were substantially in excess of the respective reporting units’ carrying value. Intangible assets Key judgments in accounting for intangible assets include determining the useful life and classification between goodwill and indefinite-lived intangible assets or other amortizing intangible assets. Indefinite-lived intangible assets ($2.6 billion at Dec. 31, 2025) are evaluated for impairment at least annually by comparing their fair values, estimated using discounted cash flow analyses, to their carrying values. As a result of the annual evaluation, no impairment was recognized. Other amortizing intangible assets ($234 million at Dec. 31, 2025) are evaluated for impairment if events and circumstances indicate a possible impairment. Such evaluation of other intangible assets would be initially based on undiscounted cash flow projections. Determining the fair value of a reporting unit or indefinite-lived intangible assets is subject to uncertainty as it is reliant on estimates of cash flows that extend far into the future, and, by their nature, are difficult to estimate over such an extended time frame. In the future, changes in the assumptions or the discount rate could produce a material non-cash goodwill or intangible asset impairment. See Notes 1 and 6 of the Notes to Consolidated Financial Statements for additional information regarding goodwill, intangible assets and the annual and interim impairment testing. Litigation and regulatory contingencies Significant estimates and judgments are required in establishing an accrued liability for litigation and regulatory contingencies. For additional information on our policy, see “Legal proceedings” in Note 21 of the Notes to Consolidated Financial Statements. 24 BNY Results of Operations (continued) Consolidated balance sheet review One of our key risk management objectives is to maintain a balance sheet that remains strong throughout market cycles to meet the expectations of our major stakeholders, including our shareholders, clients, creditors and regulators. We also seek to undertake overall liquidity risk, including intraday liquidity risk, that stays within our risk appetite. The objective of our balance sheet management strategy is to maintain a balance sheet that is characterized by strong liquidity and asset quality, ready access to external funding sources at competitive rates and a strong capital structure that supports our risk-taking activities and is adequate to absorb potential losses. In managing the balance sheet, appropriate consideration is given to balancing the competing needs of maintaining sufficient levels of liquidity and complying with applicable regulations and supervisory expectations while optimizing profitability. At Dec. 31, 2025, total assets were $472 billion, compared with $416 billion at Dec. 31, 2024. The increase in total assets was primarily driven by higher interest-bearing deposits with the Federal Reserve and other central banks, securities and loans. Deposits totaled $332 billion at Dec. 31, 2025, compared with $290 billion at Dec. 31, 2024. The increase primarily reflects higher interest-bearing deposits. Total interest-bearing deposit liabilities as a percentage of total interest-earning assets were 66% at Dec. 31, 2025 and 65% at Dec. 31, 2024. At Dec. 31, 2025, available funds totaled $176 billion and include cash and due from banks, interest-bearing deposits with the Federal Reserve and other central banks, interest-bearing deposits with banks and federal funds sold and securities purchased under resale agreements. This compares with available funds of $144 billion at Dec. 31, 2024. Total available funds as a percentage of total assets were 37% at Dec. 31, 2025 and 35% at Dec. 31, 2024. For additional information on our available funds, see “Liquidity and dividends.” Securities were $150 billion, or 32% of total assets, at Dec. 31, 2025, compared with $137 billion, or 33% of total assets, at Dec. 31, 2024. The increase primarily reflects higher U.S. Treasury and non-U.S. government securities and unrealized pre-tax gains in 2025, partially offset by lower U.S. government agency securities. For additional information on our securities portfolio, see “Securities” and Note 3 of the Notes to Consolidated Financial Statements. Loans were $81 billion, or 17% of total assets, at Dec. 31, 2025, compared with $72 billion, or 17% of total assets, at Dec. 31, 2024. The increase was driven by higher margin loans, other loans and wealth management loans, partially offset by lower overdrafts. For additional information on our loan portfolio, see “Loans” and Note 4 of the Notes to Consolidated Financial Statements. Long-term debt totaled $31.9 billion at Dec. 31, 2025 and $30.9 billion at Dec. 31, 2024. The increase primarily reflects issuances and an increase in the fair value of hedged long-term debt partially offset by maturities and redemptions. For additional information on long-term debt, see “Liquidity and dividends” and Note 12 of the Notes to Consolidated Financial Statements. The Bank of New York Mellon Corporation total shareholders’ equity totaled $44 billion at Dec. 31, 2025 and $41 billion at Dec. 31, 2024. For additional information, see “Capital” and Note 14 of the Notes to Consolidated Financial Statements. BNY 25 Results of Operations (continued) Securities In the discussion of our securities portfolio, we have included certain credit ratings information because the information can indicate the degree of credit risk to which we are exposed. Significant changes in ratings classifications could indicate increased credit risk for us and could be accompanied by an increase in the allowance for credit losses and/or a reduction in the fair value of our securities portfolio. The following table shows the distribution of our total securities portfolio. [[GREPCENT_TABLE]] [["Securities portfolio","Dec. 31, 2024","","2025 change in unrealized gain (loss)","Dec. 31, 2025","","Fair value as a % of amortizedcost (a)","Unrealized (loss)","","% Floatingrate (b)","","Ratings (c)"],["","","","","","","BBB+/ BBB-","BB+ and lower"],["(dollars in millions)","Fair value","","Amortizedcost (a)","Fair value","","","","AAA/ AA-","A+/ A-","Not rated"],["Agency residential mortgage-backed securities (\u201cRMBS\u201d)","$","42,183","","","$","1,703","","$","47,696","","$","45,383","","","95","%","$","(2,313)","","","14","%","","100","%","\u2014","%","\u2014","%","\u2014","%","\u2014","%"],["Non-U.S. government (d)","29,198","","","300","","34,247","","34,224","","","100","","(23)","","","22","","","84","","16","","\u2014","","\u2014","","\u2014"],["U.S. Treasury","24,793","","","550","","33,451","","33,386","","","100","","(65)","","","33","","","100","","\u2014","","\u2014","","\u2014","","\u2014"],["Agency commercial mortgage-backed securities (\u201cMBS\u201d)","10,377","","","257","","9,828","","9,600","","","98","","(228)","","","44","","","100","","\u2014","","\u2014","","\u2014","","\u2014"],["Foreign covered bonds (e)","7,623","","","43","","8,824","","8,806","","","100","","(18)","","","35","","","100","","\u2014","","\u2014","","\u2014","","\u2014"],["Collateralized loan obligations (\u201cCLOs\u201d)","7,637","","","(12)","","7,958","","7,958","","","100","","\u2014","","","100","","","100","","\u2014","","\u2014","","\u2014","","\u2014"],["U.S. government agencies","5,636","","","171","","4,195","","4,029","","","96","","(166)","","","27","","","100","","\u2014","","\u2014","","\u2014","","\u2014"],["Non-agency commercial MBS","2,487","","","70","","2,280","","2,196","","","96","","(84)","","","46","","","100","","\u2014","","\u2014","","\u2014","","\u2014"],["Non-agency RMBS","1,492","","","39","","1,629","","1,515","","","93","","(114)","","","46","","","100","","\u2014","","\u2014","","\u2014","","\u2014"],["Other asset-backed securities","615","","","18","","397","","376","","","95","","(21)","","","21","","","100","","\u2014","","\u2014","","\u2014","","\u2014"],["Other","10","","","\u2014","","11","","10","","","91","","(1)","","","\u2014","","","\u2014","","\u2014","","\u2014","","\u2014","","100"],["Total securities","$","132,051","","","$","3,139","","$","150,516","","$","147,483","","","98","%","$","(3,033)","","(f)","29","%","","96","%","4","%","\u2014","%","\u2014","%","\u2014","%"]] [[/GREPCENT_TABLE]] (a)    Amortized cost includes the impact of hedged item basis adjustments, which was a net decrease of $910 million, and is net of the allowance for credit losses. (b)    Includes the impact of hedges. (c)    Represents ratings by Standard & Poor’s (“S&P”) or the equivalent. (d)    Includes supranational securities. Primarily consists of exposure to the UK, France, Germany, the Netherlands and Canada. (e)    Primarily consists of exposure to Canada, the UK, Germany, Australia, the Netherlands and Singapore. (f)    At Dec. 31, 2025, includes a pre-tax net unrealized loss of $316 million related to available-for-sale securities, net of hedges, and $2,717 million related to held-to-maturity securities. The after-tax unrealized loss, net of hedges, related to available-for-sale securities was $241 million and the after-tax unrealized loss related to held-to-maturity securities was $2,072 million. The fair value of our securities portfolio was $147.5 billion at Dec. 31, 2025, compared with $132.1 billion at Dec. 31, 2024. The increase primarily reflects higher U.S. Treasury and non-U.S. government securities and unrealized pre-tax gains in 2025, partially offset by lower U.S. government agency securities. At Dec. 31, 2025, the securities portfolio had a net unrealized loss, including the impact of related hedges, of $3.0 billion, compared with $6.2 billion at Dec. 31, 2024. The improvement in the net unrealized loss, including the impact of related hedges, was primarily driven by the impact of lower interest rates. The fair value of the available-for-sale securities totaled $102.1 billion at Dec. 31, 2025, or 69% of the securities portfolio. The fair value of the held-to- maturity securities totaled $45.4 billion at Dec. 31, 2025, or 31% of the securities portfolio. The unrealized loss (after-tax) on our available-for-sale securities portfolio, net of hedges, included in accumulated other comprehensive income was $241 million at Dec. 31, 2025, compared with $1.2 billion at Dec. 31, 2024. The improvement in the net unrealized loss, including the impact of related hedges, was primarily driven by the impact of lower interest rates. At Dec. 31, 2025, 96% of the securities in our portfolio were rated AAA/AA-, compared with 99% at Dec. 31, 2024. See Note 3 of the Notes to Consolidated Financial Statements for the pre-tax net securities gains (losses) by security type. See Note 19 of the Notes to 26 BNY Results of Operations (continued) Consolidated Financial Statements for securities by level in the fair value hierarchy. The following table presents the net premium (discount) and net amortization (accretion) related to the securities portfolio. [[GREPCENT_TABLE]] [["Net premium (discount) and net amortization (accretion) related to the securities portfolio (a)"],["(in millions)","2025","2024","2023"],["Net purchase premium (discount) that is amortizable (accretable)","$","(1,979)","","$","(57)","","$","821"],["Net amortization (accretion) (b)","$","(188)","","$","26","","$","167"]] [[/GREPCENT_TABLE]] (a)    Amortization of purchase premium decreases net interest income while accretion of discount increases net interest income. Both are recorded on a level yield basis. (b)    Including the impact of the accretion of discontinued hedges, net amortization (accretion) was $(409) million in 2025, $(149) million in 2024 and $104 million in 2023. Equity investments We have several equity investments recorded in other assets. These include tax credit investments, equity method investments, Federal Reserve Bank stock, other investments, seed capital and Federal Home Loan Bank stock. The following table presents the carrying values at Dec. 31, 2025 and Dec. 31, 2024. [[GREPCENT_TABLE]] [["Equity investments","Dec. 31,"],["(in millions)","2025","2024"],["Tax credit investments","$","3,151","","$","2,821"],["Equity method investments:"],["CIBC Mellon","678","","583"],["Siguler Guff","227","","228"],["Other","48","","41"],["Total equity method investments","953","","852"],["Federal Reserve Bank stock","484","","478"],["Other equity investments (a)","701","","679"],["Seed capital (b)","207","","196"],["Federal Home Loan Bank stock","57","","57"],["Total equity investments","$","5,553","","$","5,083"]] [[/GREPCENT_TABLE]] (a)    Includes strategic equity, private equity and other investments. (b)    Includes investments in BNY funds that hedge deferred incentive awards. For additional information on tax credit investments, see “Tax credit investments” in Note 7 of the Notes to Consolidated Financial Statements. For additional information on certain seed capital investments and our private equity investments, see “Investments valued using net asset value (“NAV”) per share” in Note 7 of the Notes to Consolidated Financial Statements. BNY 27 Results of Operations (continued) Loans  [[GREPCENT_TABLE]] [["Total exposure \u2013 consolidated","Dec. 31, 2025","","Dec. 31, 2024"],["(in billions)","Loans","Unfunded commitments","Total exposure","","Loans","Unfunded commitments","Total exposure"],["Financial institutions","$","13.3","","$","30.3","","$","43.6","","","$","13.2","","$","35.2","","$","48.4"],["Commercial","1.7","","12.9","","14.6","","","1.4","","11.9","","13.3"],["Wealth management loans","9.5","","0.8","","10.3","","","8.7","","0.7","","9.4"],["Wealth management mortgages","8.6","","0.2","","8.8","","","8.9","","0.2","","9.1"],["Commercial real estate","6.7","","3.2","","9.9","","","6.8","","3.1","","9.9"],["Other residential mortgages","1.8","","\u2014","","1.8","","","1.1","","\u2014","","1.1"],["Overdrafts","2.8","","\u2014","","2.8","","","3.5","","\u2014","","3.5"],["Capital call financing","5.3","","3.5","","8.8","","","5.2","","3.1","","8.3"],["Other (a)","4.6","","\u2014","","4.6","","","3.7","","\u2014","","3.7"],["Margin loans","26.3","","0.3","","26.6","","","19.1","","\u2014","","19.1"],["Total","$","80.6","","$","51.2","","$","131.8","","","$","71.6","","$","54.2","","$","125.8"]] [[/GREPCENT_TABLE]] (a)    Beginning in 2025, lease financings are included in Other. Prior period has been conformed to current presentation. At Dec. 31, 2025, our total lending-related exposure was $131.8 billion, an increase of 5% compared with Dec. 31, 2024, primarily reflecting higher margin loans, other loans and exposure in the commercial portfolio, partially offset by lower exposure in the financial institutions portfolio. Our financial institutions and commercial portfolios comprise our largest concentrated risk. These portfolios comprised 44% of our total exposure at Dec. 31, 2025 and 49% at Dec. 31, 2024. Additionally, most of our overdrafts relate to financial institutions. Financial institutions The financial institutions portfolio is shown below. [[GREPCENT_TABLE]] [["Financial institutionsportfolio exposure(dollars in billions)","Dec. 31, 2025","","Dec. 31, 2024"],["Loans","Unfunded commitments","Total exposure","% Inv. grade","% due 1 yr.","","Loans","Unfunded commitments","Total exposure"],["Securities industry","$","3.5","","$","15.1","","$","18.6","","100","%","98","%","","$","2.3","","$","20.3","","$","22.6"],["Asset managers","1.8","","7.6","","9.4","","98","","72","","","1.8","","8.4","","10.2"],["Banks","7.7","","1.6","","9.3","","83","","93","","","8.9","","1.4","","10.3"],["Insurance","\u2014","","4.5","","4.5","","100","","14","","","\u2014","","4.2","","4.2"],["Government","\u2014","","0.6","","0.6","","100","","25","","","\u2014","","0.4","","0.4"],["Other","0.3","","0.9","","1.2","","100","","16","","","0.2","","0.5","","0.7"],["Total","$","13.3","","$","30.3","","$","43.6","","96","%","79","%","","$","13.2","","$","35.2","","$","48.4"]] [[/GREPCENT_TABLE]] The financial institutions portfolio exposure was $43.6 billion at Dec. 31, 2025, a decrease of 10% compared with Dec. 31, 2024, primarily reflecting lower exposure in the securities industry and banks portfolios. Financial institution exposures are high-quality, with 96% of the exposures meeting the investment grade equivalent criteria of our internal credit rating classification at Dec. 31, 2025. Each customer is assigned an internal credit rating, which is mapped to an equivalent external rating agency grade based upon a number of dimensions, which are continually evaluated and may change over time. For ratings of non-U.S. counterparties, our internal credit rating is generally capped at a rating equivalent to the sovereign rating of the country where the counterparty resides, regardless of the internal credit rating assigned to the counterparty or the underlying collateral. The exposure to financial institutions is generally short-term, with 79% of the exposures expiring within one year. At Dec. 31, 2025, 19% of the exposure to financial institutions had an expiration within 90 days, compared with 18% at Dec. 31, 2024. 28 BNY Results of Operations (continued) In addition, 64% of the financial institutions exposure is secured at Dec. 31, 2025. For example, securities industry clients and asset managers often borrow against marketable securities held in custody. At Dec. 31, 2025, the secured intraday credit provided to dealers in connection with their tri-party repo activity totaled $9.3 billion and was included in the securities industry portfolio. Dealers secure the outstanding intraday credit with high-quality liquid collateral having a market value in excess of the amount of the outstanding credit. Secured intraday credit facilities represent 21% of the exposure in the financial institutions portfolio and are reviewed and reapproved annually. The asset managers portfolio exposure is high-quality, with 98% of the exposures meeting our investment grade equivalent ratings criteria as of Dec. 31, 2025. These exposures are generally short-term liquidity facilities, with the majority to regulated mutual funds. Our banks portfolio exposure primarily relates to our global trade finance. These exposures are short-term in nature, with 93% due in less than one year. The investment grade percentage of our banks exposure was 83% at Dec. 31, 2025, compared with 85% at Dec. 31, 2024. Our non-investment grade exposures are primarily trade finance loans in Brazil. Commercial The commercial portfolio is presented below. [[GREPCENT_TABLE]] [["Commercial portfolio exposure","Dec. 31, 2025","","Dec. 31, 2024"],["(dollars in billions)","Loans","Unfunded commitments","Total exposure","% Inv. grade","% due 1 yr.","","Loans","Unfunded commitments","Total exposure"],["Services and other","$","0.8","","$","4.0","","$","4.8","","99","%","27","%","","$","0.7","","$","3.5","","$","4.2"],["Manufacturing","0.7","","4.0","","4.7","","99","","26","","","0.5","","3.5","","4.0"],["Energy and utilities","0.2","","4.1","","4.3","","96","","7","","","0.2","","4.1","","4.3"],["Media and telecom","\u2014","","0.8","","0.8","","86","","27","","","\u2014","","0.8","","0.8"],["Total","$","1.7","","$","12.9","","$","14.6","","97","%","21","%","","$","1.4","","$","11.9","","$","13.3"]] [[/GREPCENT_TABLE]] The commercial portfolio exposure was $14.6 billion at Dec. 31, 2025, an increase of 10% compared with Dec. 31, 2024, primarily driven by higher exposure in the manufacturing and services and other portfolios. Our credit strategy is to focus on investment grade clients that are active users of our non-credit services. The following table summarizes the percentage of the financial institutions and commercial portfolio exposures that are investment grade. [[GREPCENT_TABLE]] [["Investment grade percentages","Dec. 31,"],["2025","2024","2023"],["Financial institutions","96","%","96","%","92","%"],["Commercial","97","%","96","%","94","%"]] [[/GREPCENT_TABLE]] Wealth management loans Our wealth management loan exposure was $10.3 billion at Dec. 31, 2025, compared with $9.4 billion at Dec. 31, 2024. Wealth management loans primarily consist of loans to high-net-worth individuals, a majority of which are secured by the customers’ investment management accounts or custody accounts. Wealth management mortgages Our wealth management mortgage exposure was $8.8 billion at Dec. 31, 2025, compared with $9.1 billion at Dec. 31, 2024. Wealth management mortgages primarily consist of loans to high-net-worth individuals, which are secured by residential property. Wealth management mortgages are primarily interest-only, adjustable-rate mortgages with a weighted-average loan-to-value ratio of 61% at origination. Less than 1% of the mortgages were past due at Dec. 31, 2025. At Dec. 31, 2025, the wealth management mortgage portfolio consisted of the following geographic concentrations: California – 20%; New York – 14%; Florida – 11%; Massachusetts – 8%; and other – 47%. BNY 29 Results of Operations (continued) Commercial real estate The composition of the commercial real estate portfolio by asset class, including percentage secured, is presented below. [[GREPCENT_TABLE]] [["Composition of commercial real estate portfolio by asset class","Dec. 31, 2025","","Dec. 31, 2024"],["","Total exposure","Percentagesecured (a)","","Total exposure","Percentagesecured (a)"],["(dollars in billions)"],["Residential","$","4.2","","87","%","","$","4.2","","88","%"],["Office","2.4","","74","","","2.4","","75"],["Retail","0.8","","55","","","0.7","","58"],["Mixed-use","0.8","","28","","","0.7","","32"],["Hotels","0.6","","38","","","0.6","","33"],["Healthcare","0.6","","35","","","0.7","","43"],["Other","0.5","","63","","","0.6","","65"],["Total commercial real estate","$","9.9","","69","%","","$","9.9","","71","%"]] [[/GREPCENT_TABLE]] (a)    Represents the percentage of secured exposure in each asset class. Our commercial real estate exposure totaled $9.9 billion at Dec. 31, 2025 and Dec. 31, 2024. Our income-producing commercial real estate facilities are focused on experienced owners and are structured with moderate leverage based on existing cash flows. Our commercial real estate lending activities also include construction and renovation facilities. Our client base consists of experienced developers and long-term holders of real estate assets. Loans are approved on the basis of existing or projected cash flows and supported by appraisals and knowledge of local market conditions. Development loans are structured with moderate leverage, and in many instances, involve some level of recourse to the developer. At Dec. 31, 2025, the unsecured portfolio consisted of real estate investment trusts (“REITs”) and real estate operating companies, which are both primarily investment grade. At Dec. 31, 2025, our commercial real estate portfolio consisted of the following concentrations: New York metro – 33%; REITs and real estate operating companies – 31%; and other – 36%. Other residential mortgages The other residential mortgages portfolio primarily consists of 1-4 family residential mortgage loans and totaled $1.8 billion at Dec. 31, 2025 and $1.1 billion at Dec. 31, 2024. Overdrafts Overdrafts primarily relate to custody and securities clearance clients and are generally repaid within two business days. Capital call financing Capital call financing includes loans to private equity funds that are secured by the fund investors’ capital commitments and the funds’ right to call capital. Other loans Other loans primarily include loans to consumers that are fully collateralized with equities, mutual funds and fixed-income securities. Margin loans Margin loan exposure of $26.6 billion at Dec. 31, 2025 and $19.1 billion at Dec. 31, 2024 was collateralized with marketable securities. Borrowers are required to maintain a daily collateral margin in excess of 100% of the value of the loan. Margin loans included $12 billion at Dec. 31, 2025 and $8 billion at Dec. 31, 2024 related to a term loan program that offers fully collateralized loans to broker-dealers. 30 BNY Results of Operations (continued) Maturity of loan portfolio The following table shows the maturity structure of our loan portfolio. [[GREPCENT_TABLE]] [["Maturity of loan portfolio at Dec. 31, 2025","Within 1 year","Between 1 and 5 years","Between 5 and 15 years","After 15 years","Total"],["(in millions)"],["Commercial","$","1,143","","$","506","","$","99","","$","\u2014","","$","1,748"],["Commercial real estate","1,900","","4,106","","704","","\u2014","","6,710"],["Financial institutions","10,742","","2,567","","\u2014","","\u2014","","13,309"],["Wealth management loans","8,908","","391","","221","","\u2014","","9,520"],["Wealth management mortgages","1","","27","","351","","8,207","","8,586"],["Other residential mortgages","\u2014","","18","","127","","1,675","","1,820"],["Overdrafts","2,800","","\u2014","","\u2014","","\u2014","","2,800"],["Capital call financing","1,958","","3,378","","\u2014","","\u2014","","5,336"],["Other","4,440","","12","","81","","\u2014","","4,533"],["Margin loans","25,753","","500","","\u2014","","\u2014","","26,253"],["Total","$","57,645","","$","11,505","","$","1,583","","$","9,882","","$","80,615"]] [[/GREPCENT_TABLE]] Interest rate characteristic The following table shows the interest rate characteristic of loans maturing after one year. [[GREPCENT_TABLE]] [["Interest rate characteristic of loan portfolio maturing 1 year at Dec. 31, 2025"],["(in millions)","Fixed rates","Floating rates","Total"],["Commercial","$","50","","$","555","","$","605"],["Commercial real estate","124","","4,686","","4,810"],["Financial institutions","\u2014","","2,567","","2,567"],["Wealth management loans","100","","512","","612"],["Wealth management mortgages","3,546","","5,039","","8,585"],["Other residential mortgages","1,641","","179","","1,820"],["Capital call financing","\u2014","","3,378","","3,378"],["Other","91","","2","","93"],["Margin Loans","\u2014","","500","","500"],["Total","$","5,552","","$","17,418","","$","22,970"]] [[/GREPCENT_TABLE]] BNY 31 Results of Operations (continued) Allowance for credit losses Our credit strategy is to focus on investment grade clients who are active users of our non-credit services. Our primary exposure to the credit risk of a customer consists of funded loans, unfunded contractual commitments to lend, standby letters of credit and overdrafts associated with our custody and securities clearance businesses. The following table presents the changes in our allowance for credit losses. [[GREPCENT_TABLE]] [["Allowance for credit losses activity","2025","","2024"],["(dollars in millions)"],["Beginning balance of allowance for credit losses","$","392","","","$","414"],["Provision for credit losses","(32)","","","70"],["Charge-offs:"],["Loans:"],["Commercial real estate","(25)","","","(82)"],["Wealth management mortgages","\u2014","","","(1)"],["Other residential mortgages","\u2014","","","(1)"],["Other financial instruments","\u2014","","","(9)"],["Total charge-offs","(25)","","","(93)"],["Recoveries:"],["Loans:"],["Commercial real estate","6","","","\u2014"],["Other residential mortgages","3","","","1"],["Total recoveries","9","","","1"],["Net (charge-offs)","(16)","","","(92)"],["Ending balance of allowance for credit losses","$","344","","","$","392"],["Allowance for loan losses","$","245","","","$","294"],["Allowance for lending-related commitments","74","","","72"],["Allowance for financial instruments (a)","25","","","26"],["Total allowance for credit losses","$","344","","","$","392"],["Total loans","$","80,615","","","$","71,570"],["Average loans outstanding","$","72,596","","","$","68,141"],["Net (charge-offs) recoveries of loans to average loans outstanding","(0.02)","%","","(0.14)","%"],["Net (charge-offs) recoveries of loans to total allowance for loan losses and lending-related commitments","(5.02)","","","(25.14)"],["Allowance for loan losses as a percentage of total loans","0.30","","","0.41"],["Allowance for loan losses and lending-related commitments as a percentage of total loans","0.40","","","0.51"],["Net (charge-offs) to average loans by loan category (b):"],["Commercial real estate","(0.28)","%","","(1.19)","%"],["Net (charge-offs) during the year","$","(19)","","","$","(82)"],["Average loans outstanding","$","6,804","","","$","6,915"],["Wealth management mortgages","N/A","","(0.01)","%"],["Net (charge-offs) during the year","N/A","","$","(1)"],["Average loans outstanding (b)","N/A","","$","9,062"]] [[/GREPCENT_TABLE]] (a)    Includes allowance for credit losses on federal funds sold and securities purchased under resale agreements, available-for-sale securities, held-to-maturity securities, accounts receivable, cash and due from banks and interest-bearing deposits with banks. (b)    Average loans based on month-end balances. N/A – Not applicable. The provision for credit losses was a benefit of $32 million in 2025, primarily driven by improvements in commercial real estate exposure and changes in the macroeconomic forecast. The allowance for loan losses and allowance for lending-related commitments represent management’s estimate of lifetime expected losses in our credit portfolio. This evaluation process is subject to numerous estimates and judgments. To the extent actual results differ from forecasts or management’s judgment, the allowance for credit losses may be greater or less than future charge-offs. Based on an evaluation of the allowance for credit losses as discussed in “Critical accounting estimates” and Note 1 of the Notes to Consolidated Financial Statements, we have allocated our allowance for 32 BNY Results of Operations (continued) loans and lending-related commitments as presented below. [[GREPCENT_TABLE]] [["Allocation of allowance for loan losses and lending-related commitments (a)"],["","Dec. 31,"],["","2025","","2024"],["(dollars in millions)","$","%","","$","%"],["Commercial real estate","$","262","","82","%","","$","315","","86","%"],["Financial institutions","25","","8","","","19","","5"],["Commercial","10","","3","","","20","","5"],["Capital call financing","8","","2","","","3","","1"],["Wealth management mortgages","7","","2","","","6","","1"],["Wealth management loans","5","","2","","","1","","1"],["Other residential mortgages","2","","1","","","2","","1"],["Total","$","319","","100","%","","$","366","","100","%"]] [[/GREPCENT_TABLE]] (a)    The allowance allocated to margins loans, overdrafts and other loans was insignificant at both Dec. 31, 2025 and Dec. 31, 2024. We have rarely suffered a loss on these types of loans. The allocation of the allowance for credit losses is inherently judgmental, and the entire allowance for credit losses is available to absorb credit losses regardless of the nature of the losses. Nonperforming assets The table below presents our nonperforming assets. [[GREPCENT_TABLE]] [["Nonperforming assets","Dec. 31,"],["(dollars in millions)","2025","2024"],["Nonperforming loans:"],["Commercial real estate","$","106","","$","143"],["Other residential mortgages","17","","19"],["Wealth management mortgages","17","","15"],["Total nonperforming loans","140","","177"],["Other assets owned","3","","2"],["Total nonperforming assets","$","143","","$","179"],["Nonperforming assets ratio","0.18","%","0.25","%"],["Allowance for loan losses/nonperforming loans","175.0","","166.1"],["Allowance for loan losses/nonperforming assets","171.3","","164.2"],["Allowance for loan losses and lending-related commitments/nonperforming loans","227.9","","206.8"],["Allowance for loan losses and lending-related commitments/nonperforming assets","223.1","","204.5"]] [[/GREPCENT_TABLE]] Nonperforming assets decreased $36 million compared with Dec. 31, 2024, primarily driven by lower nonperforming commercial real estate loans. See “Nonperforming assets” in Note 1 of the Notes to Consolidated Financial Statements for our policy for placing loans on nonaccrual status. Deposits We receive client deposits through the businesses in the Securities Services, Market and Wealth Services and Investment and Wealth Management segments and we rely on those deposits as a low-cost and stable source of funding. Total deposits were $331.9 billion at Dec. 31, 2025, an increase of 15%, compared with $289.5 billion at Dec. 31, 2024. The increase primarily reflects higher interest-bearing deposits. Noninterest-bearing deposits were $60.0 billion at Dec. 31, 2025 and $58.3 billion at Dec. 31, 2024. Interest-bearing deposits were primarily demand deposits and totaled $271.9 billion at Dec. 31, 2025, compared with $231.3 billion at Dec. 31, 2024. The aggregate amount of deposits by foreign customers in domestic offices was $54.9 billion at Dec. 31, 2025 and $58.8 billion at Dec. 31, 2024. Deposits in non-U.S. offices totaled $110.0 billion at Dec. 31, 2025 and $95.6 billion at Dec. 31, 2024. These deposits were primarily overnight deposits. Uninsured deposits are the portion of U.S. office deposits accounts that exceed the FDIC insurance limit. Uninsured deposits in U.S. office deposit accounts are generally demand deposits and totaled $185.9 billion at Dec. 31, 2025 and $168.9 billion at Dec. 31, 2024. Our uninsured U.S. office deposits accounts reflect the amounts disclosed in our regulatory reports, adjusted to exclude intercompany deposit balances. BNY 33 Results of Operations (continued) The following table presents the amount of uninsured U.S. and Non-U.S. office time deposits disaggregated by time remaining until maturity. [[GREPCENT_TABLE]] [["Uninsured time deposits at Dec. 31, 2025"],["(in millions)","U.S.","Non-U.S."],["Less than 3 months","$","393","","$","1,373"],["3 to 6 months","104","","5"],["6 to 12 months","110","","28"],["Over 12 months","9","","\u2014"],["Total","$","616","","$","1,406"]] [[/GREPCENT_TABLE]] Short-term borrowings We fund our operations primarily through deposits and, to a lesser extent, other short-term borrowings and long-term debt. Short-term borrowings consist of federal funds purchased and securities sold under repurchase agreements, payables to customers and broker-dealers, commercial paper and other borrowed funds. Certain short-term borrowings, for example, securities sold under repurchase agreements, require the delivery of securities as collateral. Federal funds purchased and securities sold under repurchase agreements include repurchase agreement activity with the Fixed Income Clearing Corporation (“FICC”), where we record interest expense on a gross basis, but the ending and average balances reflect the impact of offsetting under enforceable netting agreements. This activity primarily relates to government securities collateralized resale and repurchase agreements executed with clients that are novated to and settle with the FICC. Payables to customers and broker-dealers represent funds awaiting reinvestment and short sale proceeds payable on demand. Payables to customers and broker-dealers are driven by customer trading activity and market volatility. The Bank of New York Mellon issues commercial paper that matures within 397 days from the date of issue and is not redeemable prior to maturity or subject to voluntary prepayment. Other borrowed funds primarily include overdrafts of sub-custodian account balances in our Securities Services businesses, borrowings under lines of credit by our Pershing subsidiaries and borrowings from the Federal Home Loan Bank. Overdrafts typically relate to timing differences for settlements. Liquidity and dividends BNY defines liquidity as the ability of the Parent and its subsidiaries to access funding or convert assets to cash quickly and efficiently, or to roll over or issue new debt, especially during periods of market stress, at a reasonable cost, and in order to meet its short-term (up to one year) obligations. Funding liquidity risk is the risk that BNY cannot meet its cash and collateral obligations at a reasonable cost for both expected and unexpected cash flow and collateral needs without adversely affecting daily operations or our financial condition. Funding liquidity risk can arise from funding mismatches, market constraints from the inability to convert assets into cash, the inability to hold or raise cash, low overnight deposits, deposit run-off or contingent liquidity events. Changes in economic conditions or exposure to credit, market, operational, legal and reputational risks also can affect BNY’s liquidity risk profile and are considered in our liquidity risk framework. For additional information, see “Risk Management – Liquidity Risk.” The Parent’s policy is to have access to sufficient unencumbered cash and cash equivalents at each quarter-end to cover maturities and other forecasted debt redemptions, net interest payments and net tax payments for the following 18-month period, and to provide sufficient collateral to satisfy transactions subject to Section 23A of the Federal Reserve Act. We monitor and control liquidity exposures and funding needs within and across significant legal entities, branches, currencies and business lines, taking into account, among other factors, any applicable restrictions on the transfer of liquidity among entities. BNY also manages potential intraday liquidity risks. We monitor and manage intraday liquidity against existing and expected intraday liquid resources (such as cash balances, remaining intraday credit capacity, intraday contingency funding and available collateral) to enable BNY to meet its intraday obligations under normal and reasonably severe stressed conditions. 34 BNY Results of Operations (continued) We define available funds for internal liquidity management purposes as cash and due from banks, interest-bearing deposits with the Federal Reserve and other central banks, interest-bearing deposits with banks and federal funds sold and securities purchased under resale agreements. The following table presents our total available funds at period end and on an average basis. [[GREPCENT_TABLE]] [["Available funds","Dec. 31, 2025","Dec. 31, 2024","Average"],["(dollars in millions)","2025","2024","2023"],["Cash and due from banks","$","5,111","","$","4,178","","$","4,942","","$","5,383","","$","5,287"],["Interest-bearing deposits with the Federal Reserve and other central banks","116,009","","89,546","","94,403","","99,986","","103,904"],["Interest-bearing deposits with banks","10,397","","9,612","","10,929","","10,991","","13,620"],["Federal funds sold and securities purchased under resale agreements","44,892","","41,146","","41,239","","31,306","","26,077"],["Total available funds","$","176,409","","$","144,482","","$","151,513","","$","147,666","","$","148,888"],["Total available funds as a percentage of total assets","37","%","35","%","35","%","36","%","37","%"]] [[/GREPCENT_TABLE]] Total available funds were $176.4 billion at Dec. 31, 2025, compared with $144.5 billion at Dec. 31, 2024. The increase was primarily due to higher interest-bearing deposits with the Federal Reserve and other central banks. Average non-core sources of funds, such as federal funds purchased and securities sold under repurchase agreements, trading liabilities, other borrowed funds and commercial paper, were $22.8 billion for 2025 and $20.4 billion for 2024. The increase primarily reflects higher commercial paper and trading liabilities. Average interest-bearing domestic deposits were $150.0 billion for 2025 and $141.3 billion for 2024. Average foreign deposits, primarily from our European-based businesses included in the Securities Services and Market and Wealth Services segments, were $98.0 billion for 2025, compared with $92.9 billion for 2024. The changes primarily reflect client activity. Average payables to customers and broker-dealers were $16.0 billion for 2025 and $12.7 billion for 2024. Payables to customers and broker-dealers are driven by customer trading activity and market volatility. Average long-term debt was $31.9 billion for 2025 and $31.8 billion for 2024. Average noninterest-bearing deposits increased to $50.2 billion for 2025 from $49.5 billion for 2024, primarily reflecting client activity. A significant reduction of client activity in our Securities Services and Market and Wealth Services business segments would reduce our access to deposits. See “Asset/liability management” for additional factors that could impact our deposit balances. Sources of liquidity The Parent’s major sources of liquidity are access to the debt and equity markets, dividends from its subsidiaries, and cash on hand and cash otherwise made available in business-as-usual circumstances to the Parent through a committed credit facility with our intermediate holding company (“IHC”). BNY 35 Results of Operations (continued) Our ability to access the capital markets on favorable terms, or at all, is partially dependent on our credit ratings, which are as follows: [[GREPCENT_TABLE]] [["Credit ratings at Dec. 31, 2025","Moody\u2019s","","S&P","","Fitch","","Morningstar DBRS"],["Parent:"],["Long-term senior debt","Aa3","","A","","AA-","","AA"],["Subordinated debt","A2","","A-","","A","","AA (low)"],["Preferred stock","Baa1","","BBB","","BBB+","","A"],["Outlook \u2013 Parent","Stable","","Stable","","Stable","","Stable"],["The Bank of New York Mellon:"],["Long-term senior debt","Aa2","","AA-","","AA","","AA (high)"],["Subordinated debt","NR","","A","","NR","","NR"],["Long-term deposits","Aa1","","AA-","","AA+","","AA (high)"],["Short-term deposits","P-1","","A-1+","","F1+","","R-1 (high)"],["Commercial paper","P-1","","A-1+","","F1+","","R-1 (high)"],["BNY Mellon, N.A.:"],["Long-term senior debt","Aa2","(a)","AA-","","AA","(a)","AA (high)"],["Long-term deposits","Aa1","","AA-","","AA+","","AA (high)"],["Short-term deposits","P-1","","A-1+","","F1+","","R-1 (high)"],["Outlook \u2013 Banks","Stable","","Stable","","Stable","","Stable"]] [[/GREPCENT_TABLE]] (a)    Represents senior debt issuer default rating. NR – Not rated. Long-term debt totaled $31.9 billion at Dec. 31, 2025 and $30.9 billion at Dec. 31, 2024. Issuances totaling $5.8 billion and an increase in the fair value of hedged long-term debt were partially offset by maturities and redemptions of $5.5 billion. The Parent has $2.7 billion of long-term debt that will mature in 2026. The following table presents the long-term debt issued in 2025. [[GREPCENT_TABLE]] [["Debt issuances"],["(in millions)","2025"],["4.942% fixed-to-floating callable senior notes due 2031","$","1,250"],["4.729% fixed-to-floating callable senior bank notes due 2029","1,250"],["4.587% fixed-to-floating callable senior bank notes due 2027","750"],["4.441% fixed-to-floating callable senior notes due 2028","750"],["5.316% fixed-to-floating callable senior notes due 2036","750"],["SOFR + 71 bps callable senior bank notes due 2027","500"],["SOFR + 68 bps callable senior notes due 2028","500"],["Total debt issuances","$","5,750"]] [[/GREPCENT_TABLE]] In January 2026, the Parent issued $1.25 billion of fixed-to-floating rate callable senior notes maturing in 2030 with an annual fixed rate interest rate of 4.026% from issuance to, but excluding, Jan. 22, 2029, and then an annual interest rate of the compounded secured overnight financing rate (“SOFR”) plus 63.4 basis points. The Parent also issued $300 million of floating rate callable senior notes maturing in 2030 at annual interest rate of compounded SOFR plus 63 basis points. The Bank of New York Mellon may issue notes and CDs. At Dec. 31, 2025 and Dec. 31, 2024, $2.5 billion and $1.0 billion, respectively, of notes were outstanding. At Dec. 31, 2025 and Dec. 31, 2024, $4.9 billion and $1.1 billion of CDs were outstanding, respectively. The Bank of New York Mellon also issues commercial paper that matures within 397 days from the date of issue and is not redeemable prior to maturity or subject to voluntary prepayment. There was $2.0 billion and $301 million of commercial paper outstanding at Dec. 31, 2025 and Dec. 31, 2024, respectively. The average commercial paper outstanding was $2.3 billion and $1.2 billion for 2025 and 2024, respectively. Subsequent to Dec. 31, 2025, our U.S. bank subsidiaries could declare dividends to the Parent of approximately $101 million, without the need for a regulatory waiver. In addition, at Dec. 31, 2025, non-bank subsidiaries of the Parent had liquid assets of approximately $4.4 billion. Restrictions on our ability to obtain funds from our subsidiaries are 36 BNY Results of Operations (continued) discussed in more detail in “Supervision and Regulation – Capital Planning and Stress Testing – Payment of Dividends, Stock Repurchases and Other Capital Distributions” and in Note 18 of the Notes to Consolidated Financial Statements. Pershing LLC has one uncommitted line of credit in place for funding purposes that is guaranteed by the Parent for $300 million. Average borrowings under this line were less than $1 million in 2025. Pershing Limited, an indirect UK-based subsidiary of BNY, has one line of credit amounting to $150 million and Pershing Securities Limited, whose parent is Pershing Limited, has one line of credit amounting to $100 million. Both of these lines are guaranteed by the Parent. Average borrowings across these lines were less than $1 million in 2025. The double leverage ratio is the ratio of our equity investment in subsidiaries divided by our consolidated Parent company equity, which includes our noncumulative perpetual preferred stock. In short, the double leverage ratio measures the extent to which equity in subsidiaries is financed by Parent company debt. As the double leverage ratio increases, this can reflect greater demands on a company’s cash flows in order to service interest payments and debt maturities. BNY’s double leverage ratio is managed in a range considering the high level of unencumbered available liquid assets held in its principal subsidiaries (such as central bank deposit placements and government securities), the Company’s cash-generating fee-based business model, with fee revenue representing 72% of total revenue in 2025, and the dividend capacity of our banking subsidiaries. Our double leverage ratio was 118.6% at Dec. 31, 2025 and 119.7% at Dec. 31, 2024, and within the range targeted by management. Uses of funds The Parent’s major uses of funds are repurchases of common stock, payment of dividends, principal and interest payments on its borrowings, acquisitions and additional investments in its subsidiaries. In July 2025, our Board of Directors approved a 13% increase in the quarterly cash dividend on our common stock, from $0.47 to $0.53 per share. We began paying the increased quarterly cash dividend in the third quarter of 2025. In 2025, we paid $1.7 billion in dividends on our common and preferred stock. Our common stock dividend payout ratio was 27% for 2025. In 2025, we repurchased 36.8 million common shares at an average price of $96.12 per common share for a total cost of $3.5 billion. Liquidity coverage ratio (“LCR”) U.S. regulators have established an LCR that requires certain banking organizations, including BNY, to maintain a minimum amount of unencumbered high-quality liquid assets (“HQLA”) sufficient to withstand the net cash outflow under a hypothetical standardized acute liquidity stress scenario for a 30-day time horizon. The following table presents BNY’s consolidated HQLA, the average HQLA and average LCR. [[GREPCENT_TABLE]] [["Consolidated HQLA and LCR","Dec. 31, 2025","Sept. 30, 2025"],["(dollars in billions)"],["Cash (a)","$","115","","$","105"],["Securities (b)","113","","108"],["Total consolidated HQLA (c)","$","228","","$","213"],["Total consolidated HQLA \u2013 average (c)","$","209","","$","200"],["Average consolidated LCR","112","%","112","%"]] [[/GREPCENT_TABLE]] (a)    Primarily includes cash on deposit with central banks. (b)    Primarily includes securities of U.S. government-sponsored enterprises, U.S. Treasury, sovereigns and U.S. agencies. (c)    Consolidated HQLA presented before adjustments. After haircuts and the impact of trapped liquidity, consolidated HQLA totaled $165 billion at Dec. 31, 2025 and $145 billion at Sept. 30, 2025, and averaged $147 billion for the fourth quarter of 2025 and $135 billion for the third quarter of 2025. BNY and each of our affected domestic bank subsidiaries were compliant with the U.S. LCR requirements of at least 100% throughout the fourth quarter of 2025. Net stable funding ratio (“NSFR”) The NSFR is a liquidity requirement applicable to large U.S. banking organizations, including BNY. The NSFR is expressed as a ratio of the available stable funding to the required stable funding amount over a one-year horizon. Our average consolidated NSFR was 130% for the fourth quarter of 2025 and third quarter of 2025. BNY and each of our affected domestic bank subsidiaries were compliant with the NSFR BNY 37 Results of Operations (continued) requirement of at least 100% throughout the fourth quarter of 2025. Statement of cash flows The following summarizes the activity reflected on the consolidated statement of cash flows. While this information may be helpful to highlight certain macro trends and business strategies, the cash flow analysis may not be as relevant when analyzing changes in our net earnings and net assets. We believe that in addition to the traditional cash flow analysis, the discussion related to liquidity and dividends and asset/liability management herein may provide more useful context in evaluating our liquidity position and related activity. Net cash provided by operating activities was $6.7 billion in 2025, compared with $687 million in 2024. In 2025, net cash provided by operating activities primarily resulted from earnings, partially offset by changes in accruals and other, net. In 2024, net cash provided by operating activities primarily resulted from earnings, partially offset by changes in trading assets and liabilities. Net cash used for investing activities was $44.3 billion in 2025, compared with $9.5 billion in 2024. In 2025, net cash used for investing activities primarily reflects changes in interest-bearing deposits with the Federal Reserve and other central banks, a net change in loans and a net increase in the securities portfolio. In 2024, net cash used for investing activities primarily reflects changes in federal funds sold and securities purchased under resale agreements, a net increase in the securities portfolio and a net change in loans, partially offset by changes in interest-bearing deposits with the Federal Reserve and other central banks. Net cash provided by financing activities was $39.7 billion in 2025, compared with $6.3 billion in 2024. In 2025, net cash provided by financing activities primarily reflects changes in deposits and issuances of long-term debt, partially offset by repayments of long-term debt. In 2024, net cash provided by financing activities primarily reflects changes in deposits and issuances of long-term debt, partially offset by repayments of long-term debt and common stock repurchases. Capital [[GREPCENT_TABLE]] [["Capital data(dollars in millions, except per share amounts; common shares in thousands)","2025","","2024"],["At Dec. 31:"],["BNY shareholders\u2019 equity to total assets ratio","9.4","%","","9.9","%"],["BNY common shareholders\u2019 equity to total assets ratio","8.4","%","","8.9","%"],["Total BNY shareholders\u2019 equity","$","44,313","","","$","41,318"],["Total BNY common shareholders\u2019 equity","$","39,477","","","$","36,975"],["BNY tangible common shareholders\u2019 equity \u2013 Non-GAAP (a)","$","21,777","","","$","19,412"],["Book value per common share","$","57.36","","","$","51.52"],["Tangible book value per common share \u2013 Non-GAAP (a)","$","31.64","","","$","27.05"],["Closing stock price per common share","$","116.09","","","$","76.83"],["Market capitalization","$","79,897","","","$","55,139"],["Common shares outstanding","688,236","","","717,680"],["Full-year:"],["Cash dividends per common share","$","2.00","","","$","1.78"],["Common dividend payout ratio","27","%","","31","%"],["Common dividend yield","1.7","%","","2.3","%"]] [[/GREPCENT_TABLE]] (a)    See “Supplemental Information – Explanation of GAAP and Non-GAAP financial measures” beginning on page 111 for the reconciliation of these Non-GAAP measures. The Bank of New York Mellon Corporation’s total shareholders’ equity increased to $44.3 billion at Dec. 31, 2025 from $41.3 billion at Dec. 31, 2024. The increase primarily reflects capital generated through earnings, improvements in accumulated other comprehensive income and an increase in additional paid-in capital, partially offset by capital returned through common stock repurchases and dividends. The unrealized loss (after-tax) on our available-for-sale securities portfolio, net of hedges, included in accumulated other comprehensive income was $241 million at Dec. 31, 2025, compared with $1.2 billion 38 BNY Results of Operations (continued) at Dec. 31, 2024. The improvement in the net unrealized loss, including the impact of related hedges, was primarily driven by the impact of lower interest rates. In March 2025, the Parent issued 500,000 depositary shares, each representing a 1/100th interest in a share of the Parent’s Series J Noncumulative Perpetual Preferred Stock. Holders of the Series J preferred stock are entitled to receive dividends, if declared by the Parent’s Board of Directors, on March 20 and September 20 of each year, commencing Sept. 20, 2025. The Parent also issued 20,000,000 depositary shares, each representing a 1/4,000th interest in a share of the Parent’s Series K Noncumulative Perpetual Preferred Stock. Holders of the Series K preferred stock are entitled to receive dividends, if declared by the Parent’s Board of Directors, on March 20, June 20, September 20 and December 20 of each year, commencing June 20, 2025. In September 2025, the Parent redeemed all outstanding shares of its Series G preferred stock. Also in September 2025, the Parent issued 500,000 depositary shares, each representing a 1/100th interest in a share of the Parent’s Series L Noncumulative Perpetual Preferred Stock. Holders of the Series L preferred stock are entitled to receive dividends, if declared by the Parent’s Board of Directors, on June 20 and December 20 of each year, commencing Dec. 20, 2025. See Note 14 of the Notes to Consolidated Financial Statements for additional information on the Parent’s preferred stock. We repurchased 36.8 million common shares at an average price of $96.12 per common share for a total of $3.5 billion in 2025. In January 2023, we announced a share repurchase program approved by our Board of Directors providing for the repurchase of up to $5.0 billion of common shares beginning Jan. 1, 2023. This share repurchase plan replaced all previously authorized share repurchase plans. In April 2024, we announced a new authorization providing for the repurchase of $6.0 billion of common shares in addition to any remaining capacity under the existing January 2023 authorization. In July 2025, our Board of Directors approved a 13% increase in the quarterly cash dividend on common stock, from $0.47 to $0.53 per share. We began paying the increased quarterly cash dividend in the third quarter of 2025. Capital adequacy Regulators establish certain levels of capital for bank holding companies (“BHCs”) and banks, including BNY and our bank subsidiaries, in accordance with established quantitative measurements. For the Parent to maintain its status as a financial holding company (“FHC”), our U.S. bank subsidiaries and BNY must, among other things, qualify as “well capitalized.” As of Dec. 31, 2025 and Dec. 31, 2024, BNY and our U.S. bank subsidiaries were “well capitalized.” Failure to satisfy regulatory standards, including “well capitalized” status or capital adequacy rules more generally, could result in limitations on our activities and adversely affect our financial condition. See the discussion of these matters in “Supervision and Regulation – Regulated Entities of BNY and Ancillary Regulatory Requirements” and “Risk Factors – Capital and Liquidity Risk – Failure to satisfy regulatory standards, including “well capitalized” and “well managed” status or capital adequacy and liquidity rules more generally, could result in limitations on our activities and adversely affect our business and financial condition.” The U.S. banking agencies’ capital rules are based on the framework adopted by the Basel Committee on Banking Supervision (“BCBS”), as amended from time to time. For additional information on these capital requirements, see “Supervision and Regulation.” BNY 39 Results of Operations (continued) The table below presents our consolidated and largest bank subsidiary regulatory capital ratios. [[GREPCENT_TABLE]] [["Consolidated and largest bank subsidiary regulatory capital ratios","Dec. 31, 2025","","","","Dec. 31, 2024"],["Well capitalized","","Minimum required","","Capital ratios","","","","Capital ratios"],["","(a)"],["Consolidated regulatory capital ratios: (b)"],["Advanced Approaches:"],["CET1 ratio","N/A","(c)","8.5","%","","13.0","%","","","","11.7","%"],["Tier 1 capital ratio","6","%","","10","","","16.0","","","","","14.4"],["Total capital ratio","10","","","12","","","16.7","","","","","15.3"],["Standardized Approach:"],["CET1 ratio","N/A","(c)","8.5","%","","11.9","%","","","","11.2","%"],["Tier 1 capital ratio","6","%","","10","","","14.6","","","","","13.7"],["Total capital ratio","10","","","12","","","15.4","","","","","14.8"],["Tier 1 leverage ratio","N/A","(c)","4","","","6.0","","","","","5.7"],["SLR (d)","N/A","(c)","5","","","6.7","","","","","6.5"],["The Bank of New York Mellon regulatory capital ratios: (b)(e)"],["CET1 ratio","6.5","%","","7","%","","16.3","%","","","","16.1","%"],["Tier 1 capital ratio","8","","","8.5","","","16.3","","","","","16.1"],["Total capital ratio","10","","","10.5","","","16.6","","","","","16.3"],["Tier 1 leverage ratio","5","","","4","","","6.5","","","","","6.3"],["SLR (d)","6","","","3","","","7.7","","","","","7.6"]] [[/GREPCENT_TABLE]] (a)    Minimum requirements for Dec. 31, 2025 include minimum thresholds plus currently applicable buffers. The U.S. global systemically important banks (“G-SIB”) surcharge of 1.5% is subject to change. The countercyclical capital buffer is currently set to 0%. The stress capital buffer (“SCB”) requirement is 2.5%, equal to the regulatory minimum for Standardized Approach capital ratios. (b)    For our CET1, Tier 1 capital and Total capital ratios, our effective capital ratios under U.S. capital rules are the lower of the ratios as calculated under the Standardized and Advanced Approaches. The Tier 1 leverage ratio is based on Tier 1 capital and quarterly average total assets. (c)    The Federal Reserve’s regulations do not establish well capitalized thresholds for these measures for BHCs. (d)    The SLR is based on Tier 1 capital and total leverage exposure, which includes certain off-balance sheet exposures. (e)    The Bank of New York Mellon’s effective capital ratios under the U.S. capital rules are the lower of the ratios as calculated under the Standardized and Advanced Approaches, which for Dec 31, 2025 was the Standardized Approach, and for Dec. 31, 2024 was the Standardized Approach for the CET1 and Tier 1 capital ratios and the Advanced Approaches for the Total capital ratio. N/A - Not applicable. Our CET1 ratio determined under the Standardized Approach was 11.9% at Dec. 31, 2025 and 11.2% at Dec. 31, 2024. The increase was primarily driven by capital generated through earnings and a net increase in accumulated other comprehensive income, partially offset by capital returned through common stock repurchases and dividends and higher RWAs. The Tier 1 leverage ratio was 6.0% at Dec. 31, 2025, compared with 5.7% at Dec. 31, 2024. The increase was driven by an increase in capital, partially offset by higher average assets. Risk-based capital ratios vary depending on the size of the balance sheet at period end and the levels and types of investments in assets, and leverage ratios vary based on the average size of the balance sheet over the quarter. The balance sheet size fluctuates from period to period based on levels of customer and market activity. In general, when servicing clients are more actively trading securities, deposit balances and the balance sheet as a whole are higher. In addition, when markets experience significant volatility or stress, our balance sheet size may increase considerably as client deposit levels increase. Our capital ratios are necessarily subject to, among other things, anticipated compliance with all necessary enhancements to model calibration, approval by regulators of certain models used as part of RWA calculations, other refinements, further implementation guidance from regulators, market practices and standards and any changes BNY may make to its businesses. As a consequence of these factors, our capital ratios may materially change, and may be volatile over time and from period to period. Under the Advanced Approaches, our operational loss risk model is informed by external losses, including fines and penalties levied against institutions in the financial services industry, particularly those that relate to businesses in which we operate, and as a 40 BNY Results of Operations (continued) result external losses have impacted and could in the future impact the amount of capital that we are required to hold. The following table presents our capital components and RWAs, the average assets used for leverage capital purposes and leverage exposure used for SLR purposes. [[GREPCENT_TABLE]] [["Capital components and risk-weighted assets","Dec. 31,"],["(in millions)","2025","2024"],["CET1:"],["Common shareholders\u2019 equity","$","39,477","","$","36,975"],["Adjustments for:"],["Goodwill and intangible assets (a)","(17,700)","","(17,563)"],["Net pension fund assets","(375)","","(333)"],["Embedded goodwill","(258)","","(254)"],["Deferred tax assets","(54)","","(62)"],["Other","(4)","","(4)"],["Total CET1","21,086","","18,759"],["Other Tier 1 capital:"],["Preferred stock","4,836","","4,343"],["Other","(13)","","(63)"],["Total Tier 1 capital","$","25,909","","$","23,039"],["Tier 2 capital:"],["Subordinated debt","$","1,148","","$","1,398"],["Allowance for credit losses","344","","392"],["Other","(11)","","(11)"],["Total Tier 2 capital \u2013 Standardized Approach","1,481","","1,779"],["Excess of expected credit losses","\u2014","","109"],["Less: Allowance for credit losses","344","","392"],["Total Tier 2 capital \u2013 Advanced Approaches","$","1,137","","$","1,496"],["Total capital:"],["Standardized Approach","$","27,390","","$","24,818"],["Advanced Approaches","$","27,046","","$","24,535"],["Risk-weighted assets:"],["Standardized Approach","$","177,677","","$","167,786"],["Advanced Approaches:"],["Credit Risk","$","91,942","","$","90,076"],["Market Risk","4,201","","4,808"],["Operational Risk","66,275","","65,588"],["Total Advanced Approaches","$","162,418","","$","160,472"],["Average assets for Tier 1 leverage ratio","$","432,803","","$","402,069"],["Total leverage exposure for SLR","$","388,529","","$","353,523"]] [[/GREPCENT_TABLE]] (a)    Reduced by deferred tax liabilities associated with intangible assets and tax-deductible goodwill. The table below presents the factors that impacted CET1 capital. [[GREPCENT_TABLE]] [["CET1 generation","2025"],["(in millions)"],["CET1 \u2013 Beginning of period","$","18,759"],["Net income applicable to common shareholders of The Bank of New York Mellon Corporation","5,306"],["Goodwill and intangible assets, net of related deferred tax liabilities","(137)"],["Gross CET1 generated","5,169"],["Capital deployed:"],["Common stock repurchases","(3,535)"],["Common stock dividends (a)","(1,447)"],["Total capital returned","(4,982)"],["Other comprehensive gain (loss):"],["Unrealized gain on assets available-for-sale","999"],["Foreign currency translation","580"],["Unrealized (loss) on cash flow hedges","(8)"],["Defined benefit plans","50"],["Total other comprehensive gain","1,621"],["Additional paid-in capital (b)","586"],["Other additions (deductions):"],["Net pension fund assets","(42)"],["Embedded goodwill","(4)"],["Deferred tax assets","8"],["Other","(29)"],["Total other (deductions)","(67)"],["Net CET1 generated","2,327"],["CET1 \u2013 End of period","$","21,086"]] [[/GREPCENT_TABLE]] (a)    Includes dividend-equivalents on share-based awards. (b)    Primarily related to stock awards and stock issued for employee benefit plans. The following table shows the impact on the consolidated capital ratios at Dec. 31, 2025 of a $100 million increase or decrease in common equity, or a $1 billion increase or decrease in RWAs, quarterly average assets or total leverage exposure. [[GREPCENT_TABLE]] [["Sensitivity of consolidated capital ratios at Dec. 31, 2025"],["","Increase or decrease of"],["(in basis points)","$100 million in common equity","$1 billion in RWA, quarterly average assets or total leverage exposure"],["CET1:"],["Standardized Approach","6","bps","7","bps"],["Advanced Approaches","6","","8"],["Tier 1 capital:"],["Standardized Approach","6","","8"],["Advanced Approaches","6","","10"],["Total capital:"],["Standardized Approach","6","","9"],["Advanced Approaches","6","","10"],["Tier 1 leverage","2","","1"],["SLR","3","","2"]] [[/GREPCENT_TABLE]] BNY 41 Results of Operations (continued) Stress capital buffer In August 2024, the Federal Reserve announced that BNY’s SCB requirement would remain at 2.5%, equal to the regulatory floor, for the period from Oct. 1, 2024 through Sept. 30, 2025. In August 2025, the Federal Reserve announced that BNY’s SCB requirement would remain at 2.5%, equal to the regulatory floor, effective on Oct. 1, 2025, under the current capital plan rule. See “Supervision and Regulation” for additional information. Total Loss-Absorbing Capacity (“TLAC”) The following summarizes the minimum requirements for BNY’s external TLAC and external long-term debt (“LTD”) ratios, plus currently applicable buffers. [[GREPCENT_TABLE]] [["","As a % of RWAs (a)","As a % of total leverage exposure"],["Eligible external TLAC ratios","Regulatory minimum of 18% plus a buffer (b) equal to the sum of 2.5%, the method 1 G-SIB surcharge (currently 1%), and the countercyclical capital buffer, if any","Regulatory minimum of 7.5% plus a buffer (c) equal to 2%"],["Eligible external LTD ratios","Regulatory minimum of 6% plus the greater of the method 1 or method 2 G-SIB surcharge (currently 1.5%)","4.5%"]] [[/GREPCENT_TABLE]] (a)    RWA is the greater of the Standardized Approach and Advanced Approaches. (b)    Buffer to be met using only CET1. (c)    Buffer to be met using only Tier 1 capital. External TLAC consists of the Parent’s Tier 1 capital and eligible unsecured LTD issued by it that has a remaining term to maturity of at least one year and satisfies certain other conditions. Eligible LTD consists of the unpaid principal balance of eligible unsecured debt securities, subject to haircuts for amounts due to be paid within two years, that satisfy certain other conditions. Debt issued prior to Dec. 31, 2016 has been permanently grandfathered to the extent these instruments otherwise would be ineligible only due to containing impermissible acceleration rights or being governed by foreign law. The following table presents our external TLAC and external LTD ratios. [[GREPCENT_TABLE]] [["TLAC and LTD ratios","Dec. 31, 2025"],["","Minimum required","Minimum ratios with buffers"],["","Ratios"],["Eligible external TLAC:"],["As a percentage of RWA","18.0","%","21.5","%","29.7","%"],["As a percentage of total leverage exposure","7.5","%","9.5","%","13.6","%"],["Eligible external LTD:"],["As a percentage of RWA","7.5","%","N/A","14.3","%"],["As a percentage of total leverage exposure","4.5","%","N/A","6.5","%"]] [[/GREPCENT_TABLE]] N/A – Not applicable. If BNY maintains risk-based ratio or leverage TLAC measures above the minimum required level, but with a risk-based ratio or leverage below the minimum level with buffers, we will face constraints on dividends, equity repurchases and discretionary executive compensation based on the amount of the shortfall and eligible retained income. Issuer purchases of equity securities [[GREPCENT_TABLE]] [["Share repurchases \u2013 fourth quarter of 2025","","","","","Total shares repurchased as part of a publicly announced plan or program","Maximum approximate dollar value of shares that may yet be purchased under the publicly announced plans or programs at Dec. 31, 2025"],["(dollars in millions, except per share amounts; common shares in thousands)","Total shares repurchased","","Average price per share"],["October 2025","2,125","","","$","107.45","","","2,125","","","$","2,614"],["November 2025","4,410","","","109.07","","","4,410","","","2,133"],["December 2025","2,915","","","115.04","","","2,915","","","1,797"],["Fourth quarter of 2025 (a)","9,450","","","$","110.54","","","9,450","","","$","1,797","","(b)"]] [[/GREPCENT_TABLE]] (a)    Includes 113 thousand shares repurchased at a purchase price of $12 million from employees, primarily in connection with the employees’ payment of taxes upon the vesting of restricted stock. The average price of open market share repurchases was $110.56. (b)    Represents the maximum value of the shares to be repurchased under the share repurchase plan and includes shares repurchased in connection with employee benefit plans. 42 BNY Results of Operations (continued) In January 2023, we announced a share repurchase program approved by our Board of Directors providing for the repurchase of up to $5.0 billion of common shares beginning Jan. 1, 2023. This share repurchase plan replaced all previously authorized share repurchase plans. In April 2024, we announced a new authorization providing for the repurchase of $6.0 billion of common shares. Share repurchases may be executed through open market repurchases, in privately negotiated transactions or by other means, including through repurchase plans designed to comply with Rule 10b5-1 and other derivative, accelerated share repurchase and other structured transactions. The timing and exact amount of any common stock repurchases will depend on various factors, including market conditions and the common stock trading price; the Company’s capital position, liquidity and financial performance; alternative uses of capital; and legal and regulatory limitations and considerations. Trading activities and risk management Our trading activities are focused on acting as a market-maker for our customers, facilitating customer trades and risk-mitigating hedging in compliance with the Volcker Rule. The risk from market-making activities for customers is managed by our traders and limited in total exposure through a system of position limits, value-at-risk (“VaR”) methodology and other market sensitivity measures. VaR is the potential loss in value due to adverse market movements over a defined time horizon with a specified confidence level. The calculation of our VaR used by management and presented below assumes a one-day holding period, utilizes a 99% confidence level and incorporates non-linear product characteristics. VaR facilitates comparisons across portfolios of different risk characteristics. VaR also captures the diversification of aggregated risk at the firm-wide level. VaR represents a key risk management measure and it is important to note the inherent limitations to VaR, which include: •VaR does not estimate potential losses over longer time horizons where moves may be extreme; •VaR does not take into account the potential variability of market liquidity; and •Previous moves in market risk factors may not produce accurate predictions of all future market moves. See Note 22 of the Notes to Consolidated Financial Statements for additional information on the VaR methodology. The following tables indicate the calculated VaR amounts for the trading portfolio for the designated periods using the historical simulation VaR model. [[GREPCENT_TABLE]] [["VaR (a)","2025","Dec. 31, 2025"],["(in millions)","Average","Minimum","Maximum"],["Interest rate","$","7.3","","$","2.1","","$","17.9","","$","15.3"],["Foreign exchange","7.7","","1.6","","21.2","","16.6"],["Equity","0.1","","\u2014","","1.6","","0.1"],["Credit","1.0","","0.5","","2.4","","0.5"],["Diversification","(14.2)","","N/M","N/M","(31.2)"],["Overall portfolio","1.9","","1.0","","4.5","","1.3"]] [[/GREPCENT_TABLE]] [[GREPCENT_TABLE]] [["VaR (a)","2024","Dec. 31, 2024"],["(in millions)","Average","Minimum","Maximum"],["Interest rate","$","2.7","","$","1.9","","$","4.6","","$","2.6"],["Foreign exchange","2.2","","1.6","","3.0","","2.0"],["Equity","0.1","","\u2014","","1.0","","0.1"],["Credit","1.3","","0.9","","1.9","","1.5"],["Diversification","(4.4)","","N/M","N/M","(4.8)"],["Overall portfolio","1.9","","1.4","","3.0","","1.4"]] [[/GREPCENT_TABLE]] (a)    VaR exposure does not include the impact of the Company’s consolidated investment management funds and seed capital investments. N/M – Because the minimum and maximum may occur on different days for different risk components, it is not meaningful to compute a minimum and maximum portfolio diversification effect. The interest rate component of VaR represents instruments whose values are predominantly driven by interest rate levels. These instruments include, but are not limited to, U.S. Treasury securities, swaps, swaptions, forward rate agreements, exchange-traded futures and options, and other interest rate derivative products. The foreign exchange component of VaR represents instruments whose values predominantly vary with the level or volatility of currency exchange rates or interest rates. These instruments include, but are not limited to, currency balances, spot and forward transactions, currency options and other currency derivative products. BNY 43 Results of Operations (continued) The equity component of VaR consists of instruments that represent an ownership interest in the form of domestic and foreign common stock or other equity-linked instruments. These instruments include, but are not limited to, common stock, exchange-traded funds, preferred stock, listed equity options (puts and calls), OTC equity options, equity total return swaps, equity index futures and other equity derivative products. The credit component of VaR represents instruments whose values are predominantly driven by credit spread levels, i.e., idiosyncratic default risk. These instruments include, but are not limited to, single issuer credit default swaps, and securities with exposures from corporate and municipal credit spreads. The diversification component of VaR is the risk reduction benefit that occurs when combining portfolios and offsetting positions, and from the correlated behavior of risk factor movements. During 2025, interest rate risk generated 45% of average gross VaR, foreign exchange risk generated 48% of average gross VaR, equity risk generated 1% of average gross VaR and credit risk generated 6% of average gross VaR. During 2025, our daily trading loss exceeded our calculated VaR amount of the overall portfolio on three occasions. The following table of total daily trading revenue or loss illustrates the number of trading days in which our trading revenue or loss fell within particular ranges during the past five quarters. [[GREPCENT_TABLE]] [["Distribution of trading revenue (loss) (a)"],["","Quarter ended"],["(dollars in millions)","Dec. 31, 2025","Sept. 30, 2025","June 30, 2025","March 31, 2025","Dec. 31, 2024"],["Revenue range:","Number of days"],["Less than $(2.5)","\u2014","","\u2014","","1","","1","","\u2014"],["$(2.5) \u2013 $0","\u2014","","2","","2","","4","","2"],["$0 \u2013 $2.5","16","","15","","10","","16","","12"],["$2.5 \u2013 $5.0","32","","31","","28","","17","","26"],["More than $5.0","16","","16","","22","","23","","24"]] [[/GREPCENT_TABLE]] (a)    Trading revenue (loss) includes realized and unrealized gains and losses primarily related to spot and forward foreign exchange transactions, derivatives and securities trades for our customers and excludes any associated commissions, underwriting fees and net interest income. Trading assets include debt and equity instruments and derivative assets, primarily foreign exchange and interest rate contracts, not designated as hedging instruments. Trading assets were $14.3 billion at Dec. 31, 2025 and $14.0 billion at Dec. 31, 2024. Trading liabilities include debt and equity instruments and derivative liabilities, primarily foreign exchange and interest rate contracts, not designated as hedging instruments. Trading liabilities were $6.1 billion at Dec. 31, 2025 and $4.9 billion at Dec. 31, 2024. Under our fair value methodology for derivative contracts, an initial “risk-neutral” valuation is performed on each position assuming time discounting based on a AA credit curve. In addition, we consider credit risk in arriving at the fair value of our derivatives. We reflect external credit ratings as well as observable credit default swap spreads for both ourselves and our counterparties when measuring the fair value of our derivative positions. Accordingly, the valuation of our derivative positions is sensitive to the current changes in our own credit spreads, as well as those of our counterparties. At Dec. 31, 2025, our OTC derivative assets, including those in hedging relationships, of $1.4 billion included a credit valuation adjustment (“CVA”) deduction of $9 million. Our OTC derivative liabilities, including those in hedging relationships, of $2.6 billion included a debit valuation adjustment (“DVA”) of $7 million related to our own credit spread. Net of hedges, the CVA decreased by $3 million and the DVA increased by $3 million in 2025, which decreased other trading revenue by $1 million in 2025. During 2025, no realized losses were charged off against CVA reserves. At Dec. 31, 2024, our OTC derivative assets, including those in hedging relationships, of $3.7 billion included a CVA deduction of $11 million. Our OTC derivative liabilities, including those in hedging relationships, of $2.9 billion included a DVA of $7 million related to our own credit spread. Net of hedges, the CVA increased by less than $1 million and the DVA decreased by less than $1 million in 2024, which decreased other trading revenue by $1 million in 2024. During 2024, no realized loss was charged off against CVA reserves. The table below summarizes our exposure, net of collateral related to our derivative counterparties, as determined on an internal risk management basis. 44 BNY Results of Operations (continued) Significant changes in counterparty credit ratings could alter the level of credit risk faced by BNY. [[GREPCENT_TABLE]] [["Foreign exchange and other trading counterparty risk rating profile"],["","Dec. 31, 2025","","Dec. 31, 2024"],["(dollars in millions)","Exposure, net of collateral","Percentage of exposure, net of collateral","","Exposure, net of collateral","Percentage of exposure, net of collateral"],["Investment grade","$","1,078","","95","%","","$","3,201","","98","%"],["Non-investment grade","62","","5","%","","76","","2","%"],["Total","$","1,140","","100","%","","$","3,277","","100","%"]] [[/GREPCENT_TABLE]] Asset/liability management Our diversified business activities include processing securities, accepting deposits, investing in securities, lending, raising money as needed to fund assets and other transactions. The market risks from these activities include interest rate risk and foreign exchange risk. Our primary market risk is exposure to movements in U.S. dollar interest rates and certain foreign currency interest rates. We actively manage interest rate sensitivity and use earnings simulation and discounted cash flow models to identify interest rate exposures. An earnings simulation model is the primary tool used to assess changes in pre-tax net interest income between a baseline scenario and hypothetical interest rate scenarios. Interest rate sensitivity is quantified by calculating the change in pre-tax net interest income between the scenarios over a 12-month measurement period. The baseline scenario incorporates the market’s forward rate expectations and management’s assumptions regarding client deposit rates, credit spreads, changes in the prepayment behavior of loans and securities and the impact of derivative financial instruments used for interest rate risk management purposes as of each respective quarter-end. These assumptions have been developed through a combination of historical analysis and future expected pricing behavior and are inherently uncertain. Actual results may differ materially from projected results due to timing, magnitude and frequency of interest rate changes, and changes in market conditions and management’s strategies, among other factors. Client deposit levels and mix are key assumptions impacting net interest income in the baseline as well as the hypothetical interest rate scenarios. The earnings simulation model assumes static deposit levels and mix, and it also assumes that no management actions will be taken to mitigate the effects of interest rate changes. Typically, the baseline scenario uses the average deposit balances of the quarter. In the table below, we use the earnings simulation model to assess the impact of various hypothetical interest rate scenarios compared to the baseline scenario. In each of the scenarios, all currencies’ interest rates are instantaneously shifted higher or lower at the start of the forecast. Long-term interest rates are defined as all tenors equal to or greater than three years and short-term interest rates are defined as all tenors equal to or less than three months. Interim term points are interpolated where applicable. The impact of interest rate shifts may not be linear. The results of this earnings simulation should therefore not be extrapolated for more severe interest rate scenarios than those presented in the table below. The following table shows net interest income sensitivity for BNY. [[GREPCENT_TABLE]] [["Estimated changes in net interest income (in millions)","Dec. 31, 2025","Sept. 30, 2025","Dec. 31, 2024"],["Up 200 bps rate shock vs. baseline","$","(19)","","$","(19)","","$","134"],["Up 100 bps rate shock vs. baseline","30","","20","","125"],["Long-term up 100 bps, short-term unchanged","116","","102","","88"],["Short-term up 100 bps, long-term unchanged","(86)","","(82)","","37"],["Long-term down 100 bps, short-term unchanged","(126)","","(109)","","(90)"],["Short-term down 100 bps, long-term unchanged","(5)","","(8)","","(104)"],["Down 100 bps rate shock vs. baseline","(131)","","(117)","","(194)"],["Down 200 bps rate shock vs. baseline","(372)","","(309)","","(471)"]] [[/GREPCENT_TABLE]] At Dec. 31, 2025, the changes in the impacts of a 100 and 200 basis points upward or downward shift in rates on net interest income compared with Sept. 30, 2025 were primarily driven by an increase in floating-rate assets. While the net interest income sensitivity scenario calculations assume static deposit balances to facilitate consistent period-over-period comparisons, net interest income is impacted by changes in deposit balances and interest rate trajectory. Noninterest- BNY 45 Results of Operations (continued) bearing deposits are particularly sensitive to changes in short-term rates. To illustrate the net interest income sensitivity to non-interest-bearing deposits, we estimate that a $5 billion instantaneous reduction/increase in U.S. dollar-denominated noninterest-bearing deposits would reduce/increase the net interest income sensitivity results in the up 100 basis point rate shock scenario in the table above by approximately $220 million, and in the down 100 basis point rate shock scenario by approximately $120 million. The impact would be smaller if the reduction/increase was assumed to be a mixture of interest-bearing and noninterest-bearing deposits. Additionally, during periods of low short-term interest rates, money market mutual fund fees and other similar fees are typically waived to protect investors from negative returns. For a discussion of factors impacting the growth or contraction of deposits, see “Risk Factors – Capital and Liquidity Risk – Our business, financial condition and results of operations could be adversely affected if we do not effectively manage our liquidity.” We also project future cash flows from our assets and liabilities over a long-term horizon and then discount these cash flows using instantaneous parallel shocks to prevailing interest rates. This measure reflects the structural balance sheet interest rate sensitivity by discounting all future cash flows. The aggregation of these discounted cash flows is the economic value of equity (“EVE”). The following table shows how EVE would change in response to changes in interest rates. [[GREPCENT_TABLE]] [["Estimated changes in EVE","Dec. 31, 2025"],["Rate change:"],["Up 200 bps vs. baseline","(2.3)","%"],["Up 100 bps vs. baseline","(0.2)","%"],["Down 100 bps vs. baseline","(0.7)","%"],["Down 200 bps vs. baseline","(2.1)","%"]] [[/GREPCENT_TABLE]] The asymmetrical accounting treatment of the impact of a change in interest rates on our balance sheet may create a situation in which an increase in interest rates can adversely affect reported equity and regulatory capital, even though economically there may be no impact on our economic capital position. For example, an increase in rates will result in a decline in the value of our available-for-sale securities portfolio. In this example, there is no corresponding change on our fixed liabilities, even though economically these liabilities are more valuable as rates rise. These results do not reflect strategies that management could employ to limit the impact as interest rate expectations change. To manage foreign exchange risk, we fund foreign currency-denominated assets with liability instruments denominated in the same currency. We utilize various foreign exchange contracts if a liability denominated in the same currency is not available or desired, and to minimize the earnings impact of translation gains or losses created by investments in foreign markets. We use forward foreign exchange contracts to protect the value of our net investment in foreign operations. At Dec. 31, 2025, net investments in foreign operations totaled $16 billion and were spread across 18 foreign currencies. 46 BNY Risk Management Overview BNY plays a vital role in the global financial markets, and effective risk management is critical to our success. BNY operates under the Enterprise Risk Management Framework (“risk management framework”) which is the foundation of our risk management approach. Risk management begins with a strong risk culture, and we reinforce our culture through principle-based policies including the Code of Conduct, which are grounded in our core values of passion for excellence, integrity, strength in diversity and courage to lead. These values are critical to our success. They not only explain what we stand for and our shared culture, but also help us to think and act globally. They serve as a representation of the promises we have made to our clients, communities, shareholders and each other. BNY’s Risk Identification process is a core component of BNY’s risk framework and is the foundation for understanding and managing risk. We utilize a common risk language, our Risk Taxonomy, to identify risks across our primary risk categories: Operational Risk, Market Risk, Credit Risk, Liquidity Risk, Capital Risk, Model Risk and Strategic Risk. Quarterly, the Company engages in a process designed to document identification and assessment of its risks, and to determine the set of risks material to BNY. Outputs from the Risk Identification process inform elements of our risk framework such as our Risk Appetite as well as Enterprise-wide Stress Testing and Capital Planning. BNY’s Risk Appetite expresses the level of risk we are willing to tolerate to meet our strategic objectives in a manner that balances risk and reward while considering our risk capacity and maintaining a balance sheet that remains resilient throughout market cycles. This guides BNY’s risk-taking activities and informs key decision-making processes, including the manner by which we pursue our business strategy and the methods by which we manage risk. The Risk Appetite Statement and associated key risk metrics to monitor our risk profile are updated and approved by the Risk Committee of the Board at least annually. BNY conducts Enterprise-wide Stress Testing as part of its Internal Capital Adequacy Assessment Process in accordance with the Company’s Comprehensive Capital Analysis and Review (“CCAR”), and as required by the enhanced prudential standards issued pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”). Enterprise-wide Stress Testing considers the Company’s lines of business, products, geographic areas and risk types incorporating the results from underlying models and projections for a range of stress scenarios. Additional details on Capital Planning and Stress Testing are included in “Supervision and Regulation.” Three Lines of Defense BNY’s three lines of defense model is a critical component of our risk management framework to clarify roles and responsibilities across the organization. BNY’s first line of defense includes senior management and business and corporate staff, excluding management and employees in Risk Management, Compliance and Internal Audit. Senior management in the first line is responsible for maintaining and implementing an effective risk management framework and appropriately managing risk consistent with its strategy and risk tolerance, including establishing clear responsibilities and accountability for the identification, measurement, management and control of risk. Risk and Compliance is the independent second line of defense, reporting to the Chief Risk Officer. The Chief Risk Officer reports to both the Chief Executive Officer and the Risk Committee of the Board. Risk and Compliance is responsible for establishing policies, expectations and guidance for managing risk at BNY while also independently monitoring, reviewing and challenging the first line. To facilitate the comprehensive global application of consistent standards for each risk or compliance topic, independent oversight is provided by Risk and Compliance across our risk categories, businesses and legal entities. Internal Audit is BNY’s third line of defense and serves as an independent, objective assurance function that reports directly to the Audit Committee of the Board. It assists the Company in accomplishing its objectives by bringing a systematic, disciplined, risk-based approach to evaluate and improve the effectiveness of the Company’s risk management, control and governance processes. The scope of Internal Audit’s work includes the review and evaluation of the adequacy, effectiveness and sustainability of risk management procedures, internal control systems, information systems and governance processes. BNY 47 Risk Management (continued) Governance BNY’s management is responsible for execution of the Company’s risk management framework and the governance structure that supports it, with oversight provided by BNY’s Board of Directors through two key Board committees: the Risk Committee and the Audit Committee. A summary of the governance structure is provided below. [[GREPCENT_TABLE]] [["BNY Board of Directors"],["Risk Committee","","Audit Committee"],["Enterprise Risk Committee (\u201cERC\u201d)"]] [[/GREPCENT_TABLE]] [[GREPCENT_TABLE]] [["\u2022Anti-Money Laundering Oversight Committee\u2022Asset Liability Committee\u2022Compliance & Ethics Oversight Committee\u2022Consumer Risk & Compliance Committee","","\u2022Financial Risk Committee\u2022Legal Oversight Committee\u2022New Product & Activity Committee\u2022Operational Risk Committee","","\u2022Platforms Risk Committee\u2022Regulatory Oversight Committee\u2022Resolvability Steering Committee\u2022Technology Risk Committee"]] [[/GREPCENT_TABLE]] The Risk Committee is comprised entirely of independent directors and meets on a regular basis to oversee the risk management policies and practices of the Company’s global operations and oversee the Company’s global risk management framework. The roles and responsibilities of the Risk Committee are described in more detail in its charter, a copy of which is available on our website, www.bny.com. The Audit Committee is also comprised entirely of independent directors. The Audit Committee meets on a regular basis to perform an oversight review of the integrity of the financial statements and financial reporting process, compliance with legal and regulatory requirements, the Company’s independent registered public accountant’s qualifications and independence, and the performance of our internal audit function and the independent registered public accountant. The Audit Committee also reviews management’s assessment of the adequacy of internal controls. The functions of the Audit Committee are described in more detail in its charter, a copy of which is available on our website, www.bny.com. The ERC is the most senior risk committee at the management level and oversees the Company’s risk profile, monitors top and emerging risks, and evaluates significant risk/reward trade-offs. The committee is chaired by the Chief Risk Officer, and its members include the Chief Financial Officer, Chief Information Officer and Global Head of Engineering, Chief Commercial Officer and General Counsel. Subcommittees of the ERC include: •Anti-Money Laundering Oversight Committee: Oversees the systems and controls related to all aspects of Financial Crimes Compliance, including Anti-Money Laundering, Anti-Bribery & Corruption, Anti-Tax Evasion, Data & Analytics oversight, Know Your Customer, Compliance Testing and Risk Assessment, Economic Sanctions and Quality Assurance. •Asset Liability Committee (“ALCO”): Provides balance sheet oversight, including capital, liquidity and interest rate risk management. •Compliance and Ethics Oversight Committee: Provides governance and oversight of the operations of the Compliance and Ethics function and the management and reporting of compliance risk-related issues, as well as Compliance and Ethics processes, policies, procedures and standards. •Consumer Risk & Compliance Committee: Provides oversight of the Company’s consumer risk profile and related compliance with applicable laws, regulations and company policies. 48 BNY Risk Management (continued) •Financial Risk Committee: Reviews key financial risk topics including market risk, credit risk, capital management, investment portfolio, liquidity risk, and interest rate risk in the banking book, ensuring alignment with risk appetite and regulatory requirements. •Legal Oversight Committee: Oversees significant legal and regulatory matters, including internal investigation-related issues and sensitive employment-related matters. •New Product & Activity Committee: Reviews and approves proposals that seek to introduce, modify, or retire products and activities. •Operational Risk Committee: Oversees the operational risk profile and is responsible for monitoring and managing the appropriateness of the operational risk framework, policy design, adherence tracking and mitigating controls. •Platforms Risk Committee: Takes a holistic cross-platform view of risks manifesting within and between platforms, enhancing transparency of the key risk and control issues and aligning cross-platform risk reduction efforts. •Regulatory Oversight Committee: Provides strategic direction, oversight, challenge, and coordination across regulatory remediation initiatives. •Resolvability Steering Committee: Establishes program governance and oversight framework for BNY Recovery and Resolution Plans and associated activities. •Technology Risk Committee: Oversees the technology risk profile and is responsible for identifying, assessing, adjudicating, and mitigating risks stemming from technology practices. Risk Types Overview The understanding, identification, measurement and mitigation of risk are essential elements for the successful management of BNY. We leverage a comprehensive risk taxonomy to support consistent language for defining and understanding risks. The primary categories in our risk taxonomy are: [[GREPCENT_TABLE]] [["Type of risk","Description"],["Operational","The risk of loss and/or regulatory, legal or reputational impact resulting from inadequate or failed internal processes, people and systems or from external events. Operational risk includes risks, such as data, fraud, third party, compliance and financial crimes, and technology."],["Market","The risk of financial loss or adverse change to the economic condition of BNY resulting from movements in market risk factors. Market risk factors include, but are not limited to, interest rates, credit spreads, foreign exchanges rates, commodity prices, and equity prices."],["Credit","The risk of adverse financial outcomes arising from credit events (default, bankruptcy, ratings migration) associated with obligor/counterparty not meeting (inability/unwilling) its contractual obligations. Credit risk is present in the majority of our assets, but primarily concentrated in the loan and securities portfolios, as well as foreign exchange and off-balance sheet exposures such as lending commitments, letters of credit and securities lending indemnifications."],["Liquidity","The risk arising from an inability to access funding, convert assets to cash quickly and efficiently, or to roll over or issue new debt, especially during periods of market stress. Liquidity risk includes the inability to access funding sources or manage fluctuations in funding levels. Liquidity risk can arise from cash flow mismatches, market constraints from the inability to convert assets to cash, the inability to raise cash in the markets, deposit run-off or contingent liquidity events."],["Capital","The risk to capital adequacy arising from adverse changes in leverage and risk-based asset exposures as well as capital adjustments, capital deductions, composition of capital, and legal entity dynamics."],["Model","The risk of adverse consequences from business processes and/or decisions based on incorrect or misuse of model outputs and related reports. Adverse consequences could include financial loss, poor business and strategic decision-making, and/or damage to BNY\u2019s reputation."],["Strategic","The risk arising from the flawed design, decision or implementation of a business strategy, and potential disruption to business strategy by external factors and/or internal decisions. More specifically, the risks arising from adverse business decisions, poor implementation of business decisions or lack of responsiveness to changes in the financial industry and operating environment. Strategic risks may also arise from the acceptance of new businesses, the introduction or modification of products, strategic finance and risk management decisions, business process changes, complex transactions, acquisitions/divestitures/joint ventures and major capital expenditures/investments."]] [[/GREPCENT_TABLE]] BNY 49 Risk Management (continued) Operational risk In providing a comprehensive array of products and services, we are exposed to operational risk. Operational risk may result from, but is not limited to, errors related to transaction processing, failure of internal control systems and meeting compliance requirements, fraud by employees or persons outside BNY or business interruption due to system failures or other events. Operational risk may also include breaches of our technology and information systems resulting in unauthorized access to confidential information or from internal or external threats, such as cyberattacks. Operational risk also includes potential legal or regulatory actions that could arise. In the case of an operational event, we could suffer financial losses as well as reputational damage. To address these risks, we maintain comprehensive policies and procedures and an internal control framework designed to provide a sound operational environment. These controls have been designed to manage operational risk at appropriate levels given our financial strength, the business environment and markets in which we operate, and the nature of our businesses, and considering factors such as competition and regulation. The organizational framework for operational risk is based upon a strong risk culture that incorporates both governance and risk management activities. Businesses are responsible for maintaining an effective system of internal controls commensurate with the business risk profiles and in accordance with BNY policies and procedures. Operational Risk Management is the independent second line function responsible for developing risk management policies and tools for assessing, measuring, monitoring and managing operational risk for BNY. The primary objectives of the Operational Risk Management Framework are to promote effective risk management, identify emerging risks and drive improvement in controls and to reduce operational risk. The Operational Risk Management function includes independent operational risk oversight of all lines of business and functions, as well as specialist oversight of areas such as data management risk, fraud risk, and third party risk. •Data management risk: Data management risk arises when we fail to consistently manage and control our data assets through the entire lifecycle, including managing the production, confidentiality, quality, integrity, availability, and retention of data information. Our risk management approach considers data risks within our business activities. Our Data Management Framework and supporting policies address management of data in key areas of data architecture, data governance, data quality management, data protection, data usage and ethics. Emphasis is placed on data quality through data policies, regular quality assessments, and continuous improvement programs aimed at enhancing data integrity. The data architecture must be resilient and scalable to support the complex and evolving needs of the business. Efforts are made to strengthen the control environment in mitigating data management risks, aiming to achieve a higher data maturity level which enables the integration of innovative data solutions. We also consider data-related risks in the execution of our business objectives and processes, including the development of new products and services, including artificial intelligence applications. We remain committed to increasing the effectiveness of our data management practices which are designed to enable us to deliver products and services to our clients across the investment lifecycle. •Fraud risk: Fraud risk, the risk associated with an internal or external party deliberately performing an activity that relies on deception to achieve financial gain to the detriment of BNY or its clients or affiliated or related parties, is an inherent risk as part of our business. As part fraud prevention, we utilize tools which include culture and awareness campaigns, risk identification, risk assessment and risk mitigation which help us understand key fraud risks and controls and to educate employees about the expectations of identifying and reporting fraud attempts in order to protect assets of BNY and its clients. •Third party risk: Third party risk is the risk of an adverse impact on the Company due to reliance on third parties, including vendors, that provide 50 BNY Risk Management (continued) goods or perform services or other benefits on our behalf or on behalf of our clients. As part of our third-party risk management framework, we identify, evaluate, measure, mitigate, monitor and re-assess risks in an attempt to reduce the likelihood of, and negative impacts from, operational failures throughout the lifecycle of an engagement with a third party. Compliance and financial crimes risk is a subset of operational risk with second line Compliance and Ethics and Financial Crime Compliance teams. Compliance and financial crimes risk is defined as the risk of legal or regulatory sanctions, material financial loss, or a financial institution’s reputational harm as a result of its failure to comply with laws, regulations, rules, related self-regulatory organizational standards, and codes of conduct or organizational standards of practice. We seek to comply with all obligations through a comprehensive, integrated Compliance and Ethics Management Framework. Technology risk is also a subset of operational risk. Technology Risk Management is part of the second line of defense risk function providing oversight over technology risks in an effort to improve the likelihood that technology risks are identified, considered, and managed effectively against the stated risk appetite of the Company. Technology Risk Management is responsible for developing risk management policies and tools in an effort to identify and manage risks across cyber, infrastructure, applications, and resiliency and is responsible for confirming such policies and tools are well understood by the first line of defense. Further, Technology Risk Management oversees the risk reporting process through our governance and that the risks are managed within our defined risk appetite and risk management framework. Technology Risk Management uses its expertise in engaging in centralized activities and capabilities, and data-driven methodologies. Additionally, Technology Risk Management acts as a catalyst to drive the development of global technology policies, key controls, and methods to assess, measure, and monitor information and technology risk for BNY. The function also conducts integrated independent assessments on multiple cyber and digital initiatives within the Company and works to drive better understanding and a more accurate assessment of technology risks. Operational resiliency is a strategic priority for the Company. Foundational to our enterprise resiliency strategy is the Business Services Framework, governed by the first line Enterprise Resiliency Office, with second line oversight from Resiliency Risk Management. First line business management is accountable for maintaining effective resiliency capabilities under this framework, while Engineering and Operations are responsible for successful execution in coordination with the business. Elements of the resiliency strategy include the Business Services Framework, management of technology assets, Incident and Crisis Management, as well as Disaster Recovery Testing and Business Continuity capabilities. We are also focused on the resiliency capabilities of our third-party service providers. These processes are intended to position the Company to continuously deliver services to our clients through our ability to prevent, respond to and recover from business disruptions and threats. Market risk Our business activity tends to minimize our direct exposure to market risk, with such risk primarily limited to market volatility from trading activity in support of clients. More significant market risk is assumed in the form of interest rate and credit spread risk within the investment portfolio as a means for asset/liability management and net interest income generation, and also through the interest rate risk associated with BNY’s balance sheet position which is sensitive to adverse movements in interest rates. The Company has indirect market risk exposure associated with the change in the value of financial collateral underlying securities financing and derivatives positions. The Collateral Margin Review Committee reviews and approves the standards for collateral received or paid in respect of collateralized derivative agreements and securities financing transactions. The Markets business monitors its market risk through a variety of metrics including trading VaR and trading stressed VaR. Finally, the Risk Quantification Review Group reviews back-testing results for the Company’s VaR model. Credit risk We extend direct credit in order to foster client relationships and as a method by which to generate interest income from the deposits that result from business activity. We extend and incur intraday BNY 51 Risk Management (continued) credit exposure in order to facilitate our various processing activities. To balance the value of our activities with the credit risk incurred in pursuing them, we set and monitor internal credit limits for activities that entail credit risk, most often on the size of the exposure and the quality of the counterparty. For credit exposures driven by changing market rates and prices, exposure measures include an add-on for such potential changes. We manage credit risk exposure at a counterparty, industry, country and portfolio level. Credit risk exposure at the counterparty level is managed through our credit approval framework and involves four approval levels up to and including the Chief Risk Officer of the Company. The requisite approvals are based upon the size and relative risk of the aggregate exposure under consideration. The Credit Risk Group is responsible for approving the size, terms and maturity of all credit exposures proposed by the business, as well as the ongoing monitoring of the creditworthiness of the counterparty. In addition, it is responsible for challenging and approving the internal risk ratings on each exposure. The calculation of a fundamental credit measure is based on a projection of a statistically probable credit loss, used to help determine the appropriate loan loss reserve and to measure customer profitability. Credit loss considers three basic components: the estimated size of the exposure whenever default might occur, the probability of default before maturity and the severity of the loss we would incur, commonly called “loss given default.” Borrowers/counterparties are assigned ratings by the business and reviewed, challenged and approved by the Credit Portfolio Managers on an 18-grade scale, which translate to a scaled probability of default. Additionally, transactions are assigned loss given default ratings (on a 5-grade scale) that reflect the transactions’ structures, including the effects of guarantees, collateral and relative seniority of position. The Risk Modeling and Analytics Group is responsible for the calculation methodologies and the estimates of the inputs used in those methodologies for the determination of expected loss. These methodologies and input estimates are regularly evaluated for appropriateness and accuracy. As new techniques and data become available, the Risk Modeling and Analytics Group incorporates, where appropriate, those techniques or data. BNY seeks to limit both on- and off-balance sheet credit risk through prudent underwriting and the use of capital only where risk-adjusted returns warrant. We seek to manage risk and improve our portfolio diversification through syndications, asset sales, credit enhancements and active collateralization and netting agreements. In addition, we have a separate Credit Risk Review Group composed of experienced loan review officers who perform timely reviews of the loan files and credit ratings assigned to the loans. Liquidity risk Adequate liquidity is vital to BNY’s ability to process payments as well as settle and clear transactions on behalf of clients. The Company’s liquidity position can be affected by multiple factors, including funding mismatches, market conditions that impact our ability to convert our investment portfolio to cash, inability to issue debt or roll over funding, run-off of core deposits, and contingent liquidity events such as additional collateral posting requirements. Additionally, a downgrade in our credit rating cannot only lead to an outflow of deposits, which are a major source of our funding, but also increase our margin requirements on secured transactions and have a broader adverse impact on our overall brand that may further impair our ability to refinance maturing liabilities. Changes in economic conditions or exposure to other risks can also affect our liquidity. The Board of Directors approves liquidity risk tolerance and is responsible for oversight of liquidity risk management of the Company. ALCO provides governance for the appropriate execution of Board-approved strategies, policies and procedures for managing liquidity. Senior management is responsible for executing those Board-approved strategies, policies and procedures for managing liquidity which ALCO oversees, as well as regularly reporting the liquidity position of the Company to the Board of Directors. The Financial Risk Committee provides governance over independent risk oversight of financial risks, including liquidity risks, and oversees the establishment of control frameworks. BNY actively manages and monitors its cash position, quality of the investment portfolio, intraday liquidity positions and potential liquidity needs in order to support the timely payment and settlement of 52 BNY Risk Management (continued) obligations under both normal and stressed conditions. The Company uses a range of stress testing measures in connection with its efforts to maintain sufficient liquidity relative to risk appetite, including the Liquidity Coverage Ratio and Internal Liquidity Stress Testing. Capital risk Capital risk is the risk that the firm’s capital position becomes insufficient to absorb losses, support ongoing operations, and pursue strategic objectives due to adverse market conditions, losses and impairments, model errors, regulatory changes, or poor strategic planning. The Company operates under a capital management framework that is designed to ensure we have enough capital to operate under a range of conditions, meet our regulatory requirements, remain resilient to economic stress, and deploy capital in a prudent manner to optimize shareholder value. Each of the Company’s primary risks can ultimately affect capital by influencing profits and losses or through changes in Other Comprehensive Income. As capital is assessed relative to the Company’s underlying exposures through the use of capital ratios, fluctuations in leverage and risk-based exposures may lead to volatility in capital ratios. Oversight of capital management encompasses several key activities, including capital adequacy assessment, capital planning, stress testing, managing risk-weighted assets, and maintaining robust capital measurement practices. These responsibilities are carried out by independent risk management within the second line of defense. Capital oversight also includes monitoring critical programs such as the Company’s CCAR and Dodd-Frank Act Stress Test (“DFAST”) processes and review and challenge of regulatory capital requirements interpretations. Model risk Models support management of risk, our internal business processes more broadly, and our product and service offerings to clients. Among their many functions, models help us value securities, rate the quality of an obligor’s credit, establish capital needs and monitor liquidity trends. Models can have flaws in their design, underlying methodology, and implementation. Further, misuse or inappropriate application of models can also lead to model risk through a misunderstanding of model limitations/assumptions or reliance on model outputs without adequate controls or context. When this happens, the Company could be exposed to adverse consequences including financial loss, poor business decisions, and reputational harm. We aim to maintain a low-risk environment with respect to model risk. Model Risk Management is a function within our second line of defense and is responsible for developing and managing the frameworks and processes through which models are initiated, documented, validated, monitored, and governed throughout their useful life from development to retirement. These processes include enforcement of standards for developing models, risk assessment and validation of models, change control, and monitoring the ongoing performance of models. The function is independent of model developers and users. Model Risk Management’s framework includes use cases employing artificial intelligence, including large language models, and Model Risk Management is among the functions integrated into the Company’s broader, cross-functional artificial intelligence risk management framework. Model Risk Management is responsible for maintaining an active inventory of models, and models must be declared to Model Risk Management for evaluation by the Company’s staff. Strategic risk Our strategy includes, but is not limited to, improving organic growth across our businesses, delivering quality solutions and evolving our operating model. Successful realization of our strategy requires that we provide expertise, insight and market-leading and technology-enabled products and services that drive economies of scale. Additionally, it requires attracting, developing and retaining highly talented people capable of executing our strategy, while safeguarding our financial profile. Failure to achieve these objectives may negatively impact both our growth strategy and our ability to service our existing clients, resulting in potential financial loss or litigation. The markets in which we and our clients operate can evolve quickly. The introduction of new or disruptive technologies, geopolitical events and economic slowdowns are examples of factors that can create market uncertainty. Failure to anticipate or participate in transformational change within a given market or appropriately and promptly react to market BNY 53 Risk Management (continued) conditions or client preferences could result in poor strategic positioning and potential negative financial impact. While it is essential that we continue to innovate and respond to changing markets and client demand, we strive to do so in a manner that does not adversely affect our financial position or compromise our fundamental business strategy. Other Risk Considerations In addition to the primary risk categories and sub-categories noted above, we consider risks that have significance and may manifest across multiple categories of risk. These risk considerations include sustainability, reputational, and geopolitical and country risk. Sustainability risk We are exposed to sustainability risk factors that may lead to increased risk levels across one or more enterprise risk categories and may impact our risk management frameworks. For example, climate risks include physical risks from acute and chronic weather-related effects as well as transition risks from changes such as fiscal policy, legislation and regulation, technological development, and investor and customer preference changes. These effects may be wide-ranging with potential financial and operational resilience implications that could negatively impact the Company’s strategic objectives and financial performance, reputation, business operations, ability to service clients and broad stakeholder relationships. Potential risk outcomes include, but are not limited to, adverse publicity, loss of business, financial loss, litigation, employee impacts, and other operational impacts. For example, sustainability-related impacts have been identified across our credit portfolios, strategic positioning, operational resiliency, and the pace and volume of regulatory change, with the potential for reputational impacts across these areas. Thus, these risk factors are considered when managing risk within appetite and limits across the enterprise risk categories. Our reputation We are exposed to potential reputational harm as a result of negative stakeholder perception which may result from any decision, action, or inaction by BNY, any of our employees, or through other associated parties, such as clients, strategic partners, and third parties. Reputational harm could impact current or anticipated earnings, capital, liquidity, brand, and enterprise value, and can stem from any line of business, corporate function, legal entity, product, or service. Geopolitical and country risk We are exposed to the effects of geopolitical events, including tensions between nations and/or regions that may disrupt the stability of international relations, economies or markets. Geopolitical event risks include wars, trade or territorial disputes, sanctions, cybersecurity conflicts, nuclear advancements, the imposition of tariffs and retaliatory measures, shifts in alliances and government policy changes that impact global systems and stakeholders. These events can affect macroeconomic factors and financial markets which could result in losses to BNY or its clients. We are also exposed to the risks associated with maintaining commercial relationships within or connected to sovereign jurisdictions which, among other things, may not possess: an independent judiciary, a history of political pluralism, robust protections for private property (including intellectual property), traditions of free enterprise or the rule of law, or similar attributes. We monitor geopolitical events to assess and measure the potential impact on BNY. 54 BNY Cybersecurity BNY maintains a broad range of defenses aimed at remaining abreast of and responding to evolving cybersecurity threats impacting the Company, its operations, its clients, its third-party service providers and the broader financial services sector. During 2025, cybersecurity threats did not have a material effect on the Company’s business strategy or operations. However, the financial services sector is prone to cybersecurity threats, and there can be no assurance that the Company will be able to successfully protect its information systems against material cybersecurity incidents in the future. Given the increasing prevalence and severity of cybersecurity incidents affecting financial institutions, other companies and governmental agencies as well as the evolving and adaptive nature of cybersecurity threats, cybersecurity risk management is a priority for the Company that impacts its allocation of resources, operations and risk management strategy. For a further discussion of the various risks related to cybersecurity threats and the potential impact on the Company’s business strategy, results of operations or financial condition, see “Risk Factors – Operational Risk.” Risk management strategy and procedures BNY has implemented policies and procedures designed to detect, prevent and respond to malicious and accidental disruptions to the delivery of critical technology services. BNY’s cybersecurity risk management program is embedded in the Company’s three lines of defense model. As part of its first line of defense, the Company maintains a dedicated Cybersecurity organization, led by the Chief Information Security Officer (the “CISO”), that is responsible for the day-to-day management of risks from cybersecurity threats. Cybersecurity’s responsibilities include cybersecurity threat intelligence, incident response and other cybersecurity operations aimed at enabling the Company to identify, assess and manage existing and emerging cybersecurity threats. Cybersecurity monitors for potential threats and communicates relevant risks to the CISO and other members of executive management. Additionally, Cybersecurity maintains a cybersecurity incident response and reporting process pursuant to which cybersecurity incidents are classified according to their severity based upon an assessment of multiple factors. Certain cybersecurity incidents may activate enterprise-wide resiliency processes, which include, among other things, escalation through the management and Board committee structures described below. In addition, the Company maintains a preparedness program designed to reinforce cybersecurity risk management practices and compliance with the Company’s policies and procedures. The preparedness program includes mandatory training for all employees, contractors and consultants, enhanced training for those in roles presenting higher risk, calibrated phishing email simulations, distribution of information security awareness materials and cybersecurity event simulation exercises. In addition, the Company leverages both internal and external assessments and engages with third-party assessors, consultants and auditors to evaluate and test its cybersecurity controls and provide guidance on potential improvements, including design and operating effectiveness. BNY’s information security management system is certified to the ISO 27001 standard by an independent, accredited certification body, and the Company maintains this certification through periodic external audits and ongoing monitoring. The Company has standing arrangements with third parties to assist the Company in identifying, assessing and managing cybersecurity threats, including in connection with risk assessments, penetration testing, legal advice and other aspects of the Company’s cybersecurity risk management and incident response processes. As a global financial institution, BNY is subject to supervisory oversight across multiple jurisdictions, where regulators conduct periodic reviews of the Company’s cybersecurity controls for compliance with applicable laws and alignment with regulatory expectations. Insights from these independent assessments and regulatory examinations inform the ongoing enhancement of BNY’s cybersecurity program. BNY has a defined third-party governance framework to help manage the risk posed to the Company by the use of third-party service providers. The Company evaluates the risk posed by third-party service engagements based on multiple factors. The Company has protocols that seek to mitigate cybersecurity risks associated with third-party service providers based on the risk level assigned to such third party, which may include mandatory contractual obligations or the implementation of additional controls by the Company and/or the applicable service provider. BNY 55 Cybersecurity (continued) Cybersecurity is subject to ongoing review and challenge from Technology Risk Management, which is a part of the independent second line of defense risk function. Technology Risk Management, together with the broader Risk & Compliance group, is responsible for and manages the Company’s risk management framework and establishes guidance for Cybersecurity and management designed to help identify, assess and manage cybersecurity risk. For more information on how we monitor and manage our risk management framework, see “Risk Management – Overview.” Internal Audit serves as the third line of defense and provides an independent view on how effectively the organization as a whole manages cybersecurity risk. For a further discussion of BNY’s three lines of defense model, see “Risk Management – Three Lines of Defense.” Risk management oversight and governance The Company’s management is responsible for assessing and managing the Company’s material risks from cybersecurity threats with oversight provided by the Parent’s Board of Directors and the Board committees. The Risk Committee of the Board has primary responsibility for oversight of the overall operation of the Company’s risk management framework, including policies and practices addressing cybersecurity risk, and is responsible for the oversight of the second line of defense with respect to its cybersecurity risk management responsibilities. The Technology Committee of the Board and the full Board regularly receive reports and briefings from management concerning cybersecurity matters, including any significant changes to the Company’s cybersecurity program. The Company also has protocols for escalating cybersecurity threats and incidents to the Technology Committee of the Board and the full Board of Directors. In addition, the Audit Committee monitors and oversees the performance of Internal Audit, including with respect to its cybersecurity risk management responsibilities. At the management level, the Technology Oversight Committee, which is the senior management committee responsible for the governance and oversight of the Company’s significant technology projects and initiatives, reviews reports from management concerning Cybersecurity and is responsible for, among other things, escalating issues, including significant cybersecurity threats and incidents, to the Technology Committee of the Board and the full Board of Directors. The Technology Oversight Committee is chaired by the Chief Information Officer and Global Head of Engineering (the “CIO”). The Technology Risk Committee is the most senior governance committee primarily focused on cybersecurity and technology risk issues and is a part of the second line of defense risk function. It is responsible for, among other things, overseeing and reviewing emerging cybersecurity risks, significant cybersecurity incidents and remediation plans. The Technology Risk Committee receives reports from management and has protocols for escalating certain issues and risks to the ERC and the Risk Committee of the Board of Directors. The Technology Risk Committee is chaired by the Chief Technology Risk Officer. Members include key leaders from the first line of defense, including the CISO. BNY’s CIO, CISO and Chief Technology Risk Officer each have extensive experience in assessing and managing risks from cybersecurity threats. The Company’s CIO joined BNY in 2024 from a large multinational company, where she was responsible for overseeing information technology and cybersecurity operations. The Company’s CISO joined BNY in 2025 and previously led the global assurance function for cybersecurity and technology controls at a global systemically important financial institution. The Company’s Chief Technology Risk Officer joined BNY in 2024 and has previous experience as Global Head of Cyber, Technology and Information Security Risk Management at a global systemically important financial institution and over a decade of experience serving the U.S. intelligence community in a variety of cybersecurity-related positions. The Company believes that refreshing leadership in the CIO, CISO, and Chief Technology Risk Officer roles brings new perspectives and specialized expertise to enhance cybersecurity practices, while continuity is safeguarded through disciplined succession and transition planning. For a further discussion of BNY’s risk management governance structure, see “Risk Management – Governance.” 56 BNY Supervision and Regulation Evolving Regulatory Environment BNY engages in banking, investment advisory and other financial activities across the globe and is subject to extensive regulation in the jurisdictions in which it operates. Global supervisory authorities generally are charged with ensuring the safety and soundness of financial institutions, protecting the interests of customers, including depositors in banking entities and investors in mutual funds and other pooled vehicles, safeguarding the integrity of securities and other financial markets and promoting systemic resiliency and financial stability in the relevant country. They are not, however, generally charged with protecting the interests of our shareholders or non-depositor creditors. This discussion outlines the material elements of selected laws and regulations applicable to us. The impact of certain other laws and regulations, such as tax law, is discussed elsewhere in this Annual Report. Changes in these standards, or in their application, cannot be predicted, but may have a material effect on our businesses and results of operations. Since 2008, the financial services industry has been the subject of enhanced regulatory oversight. Our businesses have been subject to a significant number of global reform measures. Moreover, global political developments, including in the United States, have resulted and may continue to result in legislative and regulatory changes to key aspects of laws and regulations affecting large banking and financial institutions and in laws or regulations relating to sustainability matters. The current U.S. presidential administration has issued executive orders associated with, among other things, federal policy concerning tariffs, artificial intelligence, and digital assets. As the federal government’s posture on these and other matters continues to evolve, BNY is reviewing the impacts of these orders on its business and operations. Enhanced Prudential Standards The Federal Reserve has adopted rules (“SIFI Rules”) to implement liquidity requirements, capital stress testing and overall risk management requirements affecting U.S. systemically important financial institutions (“SIFIs”). BNY must comply with enhanced liquidity and overall risk management standards, which include maintenance of a buffer of highly liquid assets based on projected funding needs for 30 days. The liquidity buffer is in addition to the rules regarding the LCR and NSFR, discussed below, and is described by the Federal Reserve as being “complementary” to these liquidity standards. Capital Planning and Stress Testing Payment of Dividends, Stock Repurchases and Other Capital Distributions The Parent is a legal entity separate and distinct from its banks and other subsidiaries. Therefore, the Parent primarily relies on dividends, interest, distributions and other payments from its subsidiaries, including extensions of credit from the IHC, to meet its obligations, including its obligations with respect to its securities, and to provide funds for share repurchases and payment of common and preferred dividends to its stockholders, to the extent declared by the Board of Directors. Various federal and state laws and regulations limit the amount of dividends that may be paid to the Parent by our U.S. bank subsidiaries without regulatory consent. If, in the opinion of the applicable federal regulatory agency, a depository institution under its jurisdiction is engaged in or is about to engage in an unsafe or unsound practice (which, depending on the financial condition of the bank, could include the payment of dividends), the regulator may require, after notice and hearing, that the bank cease and desist from such practice. The Federal Reserve, the FDIC and the Office of the Comptroller of the Currency (“OCC,” and together, the “Agencies”) have indicated that the payment of dividends would constitute an unsafe and unsound practice if the payment would reduce a depository institution’s capital to an inadequate level. Moreover, under the Federal Deposit Insurance Act, as amended (the “FDI Act”), an insured depository institution (“IDI”) may not pay any dividends if the institution is undercapitalized or if the payment of the dividend would cause the institution to become undercapitalized. In addition, the Agencies have issued policy statements which provide that FDIC-insured depository institutions and their holding companies should generally pay dividends only out of their current operating earnings. In general, the amount of dividends that may be paid by our U.S. banking subsidiaries, including to the Parent, is limited to the lesser of the amounts calculated under a “recent earnings” test and an “undivided profits” test. Under the recent earnings test, a dividend may not be paid if the total of all BNY 57 Supervision and Regulation (continued) dividends declared and paid by the entity in any calendar year exceeds the current year’s net income combined with the retained net income of the two preceding years, unless the entity obtains prior regulatory approval. Under the undivided profits test, a dividend may not be paid in excess of the entity’s “undivided profits” (generally, accumulated net profits that have not been paid out as dividends or transferred to surplus). The ability of our U.S. bank subsidiaries to pay dividends to the Parent may also be affected by the capital adequacy standards applicable to those subsidiaries, which include minimum requirements and buffers. There are also limitations specific to the IHC’s ability to make distributions or extend credit to the Parent. The IHC is not permitted to pay dividends to the Parent if certain key capital or liquidity indicators are breached. Additionally, if our projected financial resources deteriorate so severely that resolution of the Parent becomes imminent, the committed lines of credit provided by the IHC to the Parent will automatically terminate, with all outstanding amounts becoming due. BNY’s capital distributions are subject to Federal Reserve oversight. The major component of that oversight is the Federal Reserve’s CCAR, implementing its capital plan rule. That rule requires BNY to submit annually a capital plan to the Federal Reserve. We are also required to collect and report certain related data on a quarterly basis to allow the Federal Reserve to monitor progress against the annual capital plan. On March 4, 2020, the Federal Reserve finalized an SCB rule, which made changes to the capital plan rule. The SCB rule eliminated the quantitative grounds for objection to a firm’s CCAR capital plan and introduced an SCB that became part of quarterly capital requirements of CCAR firms on Oct. 1, 2020. The final rule replaced the 2.5% capital conservation buffer with an SCB requirement for capital ratios under the U.S. capital rules’ standardized approach risk-weightings framework (“Standardized Approach”) that is based on the largest projected decrease in a firm’s CET1 ratio in the nine-quarter CCAR supervisory severely adverse scenario plus four quarters of planned common stock dividends as percentage of RWAs. The SCB is subject to a 2.5% floor. Each CCAR firm, including BNY, will be notified of its SCB by August 31, and the SCB will become effective on October 1 of the applicable calendar year. In June 2025, the Federal Reserve notified BNY that its preliminary SCB requirement would remain at 2.5%, which equals the regulatory floor. The SCB requirement was confirmed via an announcement from the Federal Reserve in August 2025 and the 2.5% requirement remains in effect. The SCB rule requires that firms reduce their planned capital actions if those distributions would cause the firm to fall below applicable buffer requirements based on the firm’s own baseline scenario projections and allows firms to increase certain planned capital distributions if they are forecasted to be above capital buffer constraints. The SCB rule also eliminates the requirement for prior approval of capital distributions in excess of the distributions in a firm’s capital plan, provided that such distributions do not cause a breach of the firm’s capital ratios, including applicable buffers. In addition, the SCB rule provides that a firm must receive prior approval for any dividend, stock repurchase or other capital distribution, other than a capital distribution on a newly issued capital instrument, if a firm is required to resubmit its capital plan. See “MD&A – Results of Operations – Capital” for information about our share repurchase program. To the extent a banking organization’s capital buffer is less than 100% of its applicable buffer requirements, its distributions and discretionary bonus payments are constrained by the amount of the shortfall and its eligible retained income. Under the final rule, eligible retained income is defined as the greater of (i) a banking organization’s net income for the four preceding calendar quarters, net of any distributions and associated tax effects not already reflected in net income, and (ii) the average of a banking organization’s net income over the preceding four quarters. The Federal Reserve made corresponding changes to the definition of “eligible retained income” in the TLAC buffer requirements. For more information on TLAC, see “Total Loss-Absorbing Capacity” below. On April 17, 2025, the Federal Reserve proposed to revise its capital plan rule to (1) measure the SCB as the average of the CET1 capital ratio declines in the Supervisory Severely Adverse scenario, as calculated by the Federal Reserve, from the two most recent supervisory stress tests, plus four quarters of planned common stock dividends as a percentage of risk-weighted assets, subject to a 2.5% floor, and (2) extend the annual effective date of the SCB by one quarter, from October 1 to January 1, so that, 58 BNY Supervision and Regulation (continued) following the supervisory stress test in a calendar year, new SCBs would generally be effective from January 1 through December 31 of the following calendar year. Although the proposal has not yet been finalized, the Company currently anticipates that the proposal will not have an impact on the Company’s SCB requirement. On Feb. 4, 2026, the Federal Reserve announced that firms will continue to be subject to their current SCB until they receive new SCBs in 2027 that can be calculated based on models that take public feedback into consideration in connection with the Oct. 24, 2025 proposal discussed under “Regulatory Stress-Testing Requirements” below. As a result, unless the Federal Reserve determines otherwise, our current SCB will remain in effect until Oct. 1, 2027. Regulatory Stress-Testing Requirements In addition to the CCAR stress testing requirements, Federal Reserve regulations also include complementary DFAST requirements. The CCAR and DFAST requirements substantially overlap, and the Federal Reserve implements them at the BHC level on a coordinated basis. Under these DFAST regulations, we are required to undergo an annual regulatory stress test conducted by the Federal Reserve. The BHC is required to conduct an annual company-run stress test. In addition, The Bank of New York Mellon is required to conduct an annual company-run stress test (although the bank is permitted to combine certain reporting and disclosure of its stress test results with the results of BNY). Results from our annual company-run stress tests are reported to the appropriate regulators and published. On Oct. 24, 2025, the Federal Reserve proposed to revise its stress testing framework to increase transparency through an enhanced disclosure and feedback process for models and scenarios used in stress testing. The Federal Reserve’s proposal includes: (1) disclosing details of and soliciting comments on the models themselves, including proposed assumptions for credit losses and operational risk, and (2) publishing the 2026 stress test scenarios for comment. In February 2026, the Federal Reserve largely adopted the 2026 stress test scenarios as proposed. BNY is assessing the outstanding proposals. Capital Requirements – Generally As a BHC, we are subject to U.S. capital rules, administered by the Federal Reserve. Our bank subsidiaries are subject to similar capital requirements administered by the Federal Reserve in the case of The Bank of New York Mellon and by the OCC in the case of our national bank subsidiaries, BNY Mellon, National Association (“BNY Mellon, N.A.”) and The Bank of New York Mellon Trust Company, National Association. These requirements are intended to ensure that banking organizations have adequate capital given the risk levels of their assets and off-balance sheet exposures. Notwithstanding the detailed U.S. capital rules, the Agencies retain significant discretion to set higher capital requirements for categories of BHCs or banks or for an individual BHC or bank as warranted. U.S. Capital Rules – Minimum Risk-Based Capital Ratios and Capital Buffers The U.S. capital rules require banking organizations subject to the advanced approaches risk-weighting framework (the “Advanced Approaches”), such as BNY, to satisfy minimum risk-based capital ratios using both the Standardized Approach and the Advanced Approaches. See “MD&A – Results of Operations – Capital” for details on these requirements. In addition, for CCAR firms, these minimum ratios are supplemented by (i) the SCB (which, for BNY, is 2.5%, as noted), in the case of a firm’s Standardized Approach capital ratios, and (ii) a capital conservation buffer of 2.5%, in the case of a firm’s Advanced Approaches capital ratios. The capital conservation buffer can only be satisfied with CET1 capital. When systemic vulnerabilities are meaningfully above normal, the SCB and capital conservation buffer may be expanded up to an additional 2.5% through the imposition of a countercyclical capital buffer. For internationally active banks such as BNY, the countercyclical capital buffer required threshold is a weighted average of the countercyclical capital buffers deployed in each of the jurisdictions in which the bank has private sector credit exposures. The Federal Reserve, in consultation with the OCC and FDIC, has affirmed the current countercyclical capital buffer level for U.S. exposures of 0% and noted that any future modifications to the buffer would generally be subject to a 12-month phase-in period. BNY 59 Supervision and Regulation (continued) Any countercyclical capital buffer required threshold arising from exposures outside the U.S. will also generally be subject to a 12-month phase-in period. For G-SIBs like BNY, the U.S. capital rules’ buffers are also supplemented by a G-SIB risk-based capital surcharge, which is the higher of the surcharges calculated under two methods (referred to as “method 1” and “method 2”). Method 1 is based on the BCBS framework and considers a G-SIB’s size, interconnectedness, cross-jurisdictional activity, substitutability and complexity. Method 2 uses similar inputs but is calibrated to result in significantly higher surcharges and replaces substitutability with a measure of reliance on short-term wholesale funding. The G-SIB surcharge applicable to BNY for 2025 was 1.5%. U.S. Capital Rules – Deductions from and Adjustments to Capital Elements The U.S. capital rules provide for a number of deductions from and adjustments to CET1 capital. These include, for example, providing that unrealized gains and losses on all available-for-sale debt securities may not be filtered out for regulatory capital purposes, and the requirement that deferred tax assets dependent upon future taxable income and significant investments in non-consolidated financial entities be deducted from CET1 to the extent that any one such category exceeds 10% of CET1 or all such categories in the aggregate exceed 15% of CET1. In addition, certain Advanced Approaches banking organizations, including BNY, are generally required to deduct from Tier 2 capital, subject to certain exceptions, direct, indirect and synthetic exposures to covered debt instruments, including TLAC instruments. U.S. Capital Rules – Advanced Approaches Risk-Based Capital Rules Under the U.S. capital rules’ Advanced Approaches framework, credit risk-weightings are generally based on risk-sensitive approaches that largely rely on the use of internal credit models and parameters, whereas, under the Standardized Approach, credit risk-weightings are generally based on supervisory risk-weightings which vary primarily by counterparty type and asset class. BNY is required to comply with Advanced Approaches reporting and public disclosures. For purposes of determining whether we meet minimum risk-based capital requirements under the U.S. capital rules, our CET1 ratio, Tier 1 capital ratio, and total capital ratio is the lower of each ratio as calculated under the Standardized Approach and under the Advanced Approaches framework (based on currently applicable buffers). U.S. Capital Rules – Standardized Approach The Standardized Approach calculates risk-weighted assets in the denominator of capital ratios using a broad array of risk-weighting categories that are intended to be risk sensitive. The risk-weights for the Standardized Approach generally range from 0% to 1,250%. Higher risk-weights under the Standardized Approach apply to a variety of exposures, including certain securitization exposures, equity exposures, claims on securities firms and exposures to counterparties on OTC derivatives. Securities finance transactions, including transactions in which we serve as agent and provide securities replacement indemnification to a securities lender, are treated as repo-style transactions under the U.S. capital rules. The rules do not permit a banking organization to use a simple VaR approach to calculate exposure amounts for repo-style transactions or to use internal models to calculate the exposure amount for the counterparty credit exposure for repo-style transactions under the Standardized Approach (although these methodologies are allowed in the Advanced Approaches). Under the Standardized Approach, a banking organization may use a collateral haircut approach to recognize the credit risk mitigation benefits of financial collateral that secures a repo-style transaction, including an agented securities lending transaction, among other transactions. To apply the collateral haircut approach, a banking organization must determine the exposure amount and the relevant risk-weight for the counterparty and collateral posted. U.S. Capital Rules – Standardized Approach for Measuring Counterparty Credit Risk Exposures for Derivatives The Agencies jointly issued the Standardized Approach for Counterparty Credit Risk (“SA-CCR”) in January 2020 amending the U.S. capital rules to implement a modified approach for calculating the exposure amount for derivative contracts. The final rule also incorporates SA-CCR into the determination of exposure amount of derivatives for total leverage 60 BNY Supervision and Regulation (continued) exposure under the SLR and the cleared transaction framework under the U.S. capital rules. SA-CCR was implemented in the first quarter of 2022. U.S. Capital Rules – Leverage Ratios The U.S. capital rules require a minimum 4% leverage ratio for all banking organizations, as well as a 3% Basel III-based SLR for Advanced Approaches banking organizations, including BNY. Unlike the Tier 1 leverage ratio, the SLR includes certain off-balance sheet exposures in the denominator, including the potential future credit exposure of derivative contracts and 10% of the notional amount of unconditionally cancelable commitments. The U.S. G-SIBs (including BNY) are subject to an enhanced SLR, which requires us to maintain an SLR of greater than 5% (composed of the current minimum requirement of 3% plus a greater than 2% buffer) and requires bank subsidiaries of those BHCs to maintain at least a 6% SLR in order to qualify as “well capitalized” under the prompt corrective action regulations discussed below. The Agencies adopted a final rule to exclude certain central bank deposits from the total leverage exposure, the SLR denominator, and related TLAC and LTD measures of custody banks, including BNY and The Bank of New York Mellon. Under the final rule, qualifying central banks include a Federal Reserve Bank, the European Central Bank or a central bank of a member country of the Organisation for Economic Co-operation and Development (“OECD”), provided that an exposure to the OECD member country receives a 0% risk-weighting and the sovereign debt of such country is not, and has not been, in default in the past five years. The central bank deposit exclusion from the SLR denominator equals the average daily balance over the applicable quarter of all deposits placed with a qualifying central bank up to an amount equal to the on-balance sheet deposit liabilities that are linked to fiduciary or custodial and safekeeping accounts. On Nov. 25, 2025, the Federal Reserve, Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation jointly issued a final rule: (i) recalibrating the Enhanced Supplementary Leverage Ratio (“eSLR”) for G-SIBs from 2% to a buffer equal to 50% of a G-SIB’s method 1 surcharge calculated under the risk-based G-SIB surcharge framework; (ii) changing the eSLR for G-SIB depository institution subsidiaries from the 6% “well capitalized” threshold under the prompt corrective action framework to a buffer equal 50% of the G-SIB parent’s method 1 surcharge calculation, capped at 1%; (iii) removing the eSLR threshold as a consideration for being “well capitalized” under the prompt corrective action framework; (iv) amending the minimum leverage-based LTD requirement for G-SIBs to the sum of the total leverage exposure multiplied by 2.5% and the recalibrated eSLR buffer standard; and (v) replacing the 2% TLAC leverage buffer with a TLAC leverage buffer equal to the recalibrated eSLR buffer standard. The compliance date is April 1, 2026. BCBS Revisions to Components of Basel III and U.S. Implementation In December 2017, the BCBS released revisions to Basel III intended to reduce variability of RWA and improve the comparability of banks’ risk-based capital ratios. In January 2019, the BCBS released revised minimum capital requirements for market risk. On July 27, 2023, the Federal Reserve, the OCC, and the FDIC proposed for comment substantial revisions to the capital requirements applicable to large banking organizations and to banking organizations with significant trading activity, including BNY, to implement the international capital standards issued by the BCBS. We will continue to monitor developments. Risk-Based Capital Surcharges for Global Systemically Important Bank Holding Companies On July 27, 2023, the Federal Reserve proposed amendments to its rule regarding risk-based capital surcharges for G-SIBs, including BNY, to revise certain systemic indicators and measures for G-SIB surcharges. We will continue to monitor developments. Total Loss-Absorbing Capacity The Federal Reserve imposes external TLAC and related requirements for U.S. G-SIBs, including BNY, at the top-tier holding company. U.S. G-SIBs are required to maintain a minimum eligible external TLAC equal to the greater of (i) 18% of RWAs plus a buffer (to be met using only CET1) equal to the sum of 2.5% of RWAs, the G-SIB BNY 61 Supervision and Regulation (continued) surcharge calculated under method 1 and any applicable countercyclical buffer; and (ii) 7.5% of their total leverage exposure (the denominator of the SLR) plus a buffer (to be met using only Tier 1 Capital) equal to 2%. U.S. G-SIBs are also required to maintain minimum external eligible LTD equal to the greater of (i) 6% of RWAs plus the G-SIB surcharge (calculated using the greater of method 1 and method 2), and (ii) 4.5% of total leverage exposure. In order to be deemed eligible LTD, debt instruments must, among other requirements, be unsecured, not be structured notes, and have a maturity of at least one year from the date of issuance. In addition, LTD issued on or after Dec. 31, 2016 must (i) not have acceleration rights, other than in the event of non-payment or the bankruptcy or insolvency of the issuer and (ii) be governed by U.S. law. However, debt issued by a U.S. G-SIB prior to Dec. 31, 2016 is permanently grandfathered to the extent these securities would be ineligible only due to containing impermissible acceleration rights or being governed by foreign law. Further, the top-tier holding companies of U.S. G-SIBs are not permitted to issue certain guarantees of subsidiary liabilities, incur liabilities guaranteed by subsidiaries, issue short-term debt to third parties, or enter into derivatives and certain other financial contracts with external counterparties. Certain liabilities are capped at 5% of the value of the U.S. G-SIB’s eligible external TLAC instruments. On Aug. 29, 2023, the Federal Reserve proposed for comment amendments to the TLAC rule applicable to U.S. G-SIBs, including BNY. The proposal would: (i) require a $400,000 minimum denomination for newly issued long-term debt of G-SIBs used to satisfy TLAC and LTD requirements; (ii) allow only 50% of the amount of eligible long-term debt with a maturity of one year or more but less than two years to count towards TLAC requirements; and (iii) exempt certain agreements from the scope of the TLAC rule’s clean holding company prohibitions with respect to qualified financial contracts with third parties. We will continue to monitor developments. Regulators in the UK and the European Union (“EU”) impose internal TLAC requirements on the foreign subsidiaries of U.S. G-SIBs. The EU’s Capital Requirements Regulation 2 (“EU CRR2”) requires EU material subsidiaries of non-EU G-SIBs (including BNY) to maintain a minimum level of internal loss absorbing capacity; this requirement continues under the EU’s proposed Capital Requirements Regulation 3 (“EU CRR3”). The BNY SA/NV is considered a material subsidiary for purposes of this regulation and is, therefore, subject to an internal TLAC requirement. Prompt Corrective Action Regarding IDI Capital Requirements The FDI Act, as amended by the Federal Deposit Insurance Corporation Improvement Act of 1991 (“FDICIA”), requires the Agencies to take “prompt corrective action” in respect of IDIs that do not meet specified capital requirements. FDICIA establishes five capital categories for FDIC-insured banks: “well capitalized,” “adequately capitalized,” “undercapitalized,” “significantly undercapitalized” and “critically undercapitalized.” The FDI Act imposes progressively more restrictive constraints on operations, management and capital distributions the less capital the institution holds. While these regulations apply only to banks, such as The Bank of New York Mellon and BNY Mellon, N.A., the Federal Reserve is authorized to take appropriate action against the parent BHC, such as the Parent, based on the undercapitalized status of any banking subsidiary. In certain circumstances, the Parent would be required to guarantee the performance of the capital restoration plan if one of our banking subsidiaries were undercapitalized. The Agencies’ prompt corrective action framework contains “well capitalized” thresholds for IDIs. Under these rules, an IDI must have the capital ratios as detailed in the “Capital” disclosure in order to satisfy the quantitative ratio requirements to be deemed “well capitalized.” Liquidity Standards – Basel III and U.S. Rules BNY is subject to the U.S. LCR Rule, which is designed to ensure that BNY and certain domestic bank subsidiaries maintain an adequate level of unencumbered HQLA equal to their expected net cash outflow for a 30-day time horizon under an acute liquidity stress scenario. As of Dec. 31, 2025, the Parent and its domestic bank subsidiaries were in compliance with applicable LCR requirements. The Agencies have issued a final NSFR rule that implements a quantitative long-term liquidity requirement applicable to large and internationally 62 BNY Supervision and Regulation (continued) active banking organizations, including BNY. Under the final rule, BNY’s NSFR is expressed as a ratio of its available stable funding to its required stable funding amount, and BNY is required to maintain an NSFR of 1.0. As of Dec. 31, 2025, BNY was in compliance with the NSFR rule. Separately, as noted above, the SIFI Rules impose additional liquidity requirements for BHCs with $100 billion or more in total assets, including BNY, including an independent review of liquidity risk management; establishment of cash flow projections; a contingency funding plan and liquidity risk limits; liquidity stress testing under multiple stress scenarios and time horizons tailored to the specific products and profile of the company; and maintenance of a liquidity buffer of unencumbered highly liquid assets sufficient to meet projected net cash outflows over 30 days under a range of stress scenarios. Volcker Rule The provisions of the Dodd-Frank Act commonly referred to as the “Volcker Rule” prohibit “banking entities,” including BNY, from engaging in proprietary trading and limit our sponsorship of, and investments in, private equity and hedge funds (“covered funds”), including our ability to own or provide seed capital to covered funds. In addition, the Volcker Rule restricts us from engaging in certain transactions with covered funds (including, without limitation, certain U.S. funds for which BNY acts as both sponsor/manager and custodian). These restrictions are subject to certain exceptions. The restrictions concerning proprietary trading contain limited exceptions for, among other things, bona fide liquidity risk management and risk-mitigating hedging activities, as well as certain classes of exempted instruments, including government securities. Ownership interests in covered funds are generally limited to 3% of the total number or value of the outstanding ownership interests of any individual fund at any time more than one year after the date of its establishment. The aggregate value of all such ownership interests in covered funds is limited to 3% of the banking organization’s Tier 1 capital, and such interests are subject to a deduction from its Tier 1 capital. The 2019 amendments to the Volcker Rule (discussed below) remove the requirements that ownership interests in third-party covered funds held under the underwriting and market-making exemptions be subject to the aggregate limit and capital deduction but preserve these requirements for ownership interests in covered funds sponsored or organized by BNY. The Volcker Rule regulations also require us to develop and maintain a compliance program. In 2019, the Agencies, the Commodity Futures Trading Commission (“CFTC”) and the SEC modified the regulations implementing the Volcker Rule. The most impactful aspects of the revisions with respect to BNY concern the compliance requirements applicable to institutions with moderate exposure to trading assets and trading liabilities, which are institutions with less than $20 billion and more than $1 billion of trading assets and trading liabilities. Specifically, among other revisions, such “moderate trading” banks are no longer required to file an annual CEO attestation and quantitative metrics. Furthermore, the comprehensive six-pillar compliance program associated with the Volcker Rule no longer applies to “moderate trading” banks; rather, such banks are permitted to tailor their compliance programs to the size and nature of their activities. BNY is treated as a “moderate trading” bank under the revised Volcker Rule. The final revisions also clarified and amended certain definitions, requirements and exemptions. On June 25, 2020, a second set of amendments to the Volcker Rule was released, which is principally focused on the restrictions on banking entities’ investments in, sponsorship of, and other relationships with covered funds. Generally, the changes establish new exclusions from the covered fund definition for certain types of investment vehicles, modify the eligibility criteria for certain existing exclusions, and clarify and modify other provisions with respect to investment in, sponsoring of, and transactions with, covered funds. Derivatives Trading and Margining Title VII of the Dodd-Frank Act imposes a comprehensive regulatory structure on the OTC derivatives markets in which BNY operates, including requirements relating to the business conduct of dealers, trade reporting, margin and recordkeeping. Title VII also requires persons acting as swap dealers, including The Bank of New York Mellon, to register with the CFTC and become subject to the CFTC’s supervisory, examination and enforcement powers. Additionally, Title VII requires BNY 63 Supervision and Regulation (continued) persons acting as security-based swap dealers to register with the SEC. The Bank of New York Mellon is registered as a security-based swap dealer. In addition, because BNY is subject to supervision by the Federal Reserve, we must comply with the U.S. prudential margin rules for variation and initial margin with respect to its OTC swap transactions. Furthermore, various BNY subsidiaries are also subject to OTC derivatives regulation by local authorities in Europe and Asia. Single Counterparty Credit Limits The Federal Reserve adopted a rule in June 2018 imposing single-counterparty credit limits (“SCCLs”) on, among other organizations, domestic BHCs, including BNY, that are G-SIBs. The SCCLs apply to the credit exposure of a covered firm and all of its subsidiaries to a single counterparty and all of its affiliates and connected entities. The rule established two primary credit exposure limits: (i) a covered domestic BHC may not have aggregate net credit exposure to any unaffiliated counterparty in excess of 25% of its Tier 1 capital; and (ii) a U.S. G-SIB is further prohibited from having aggregate net credit exposure in excess of 15% of its Tier 1 capital to any “major counterparty” (defined as a G-SIB or a non-bank SIFI). The rule provides a cure period of 90 days (or, with prior notice from the Federal Reserve, a longer or shorter period) for breaches of the SCCL rule. During the cure period, a company may not engage in additional credit transactions with the particular counterparty unless the covered company has obtained a temporary credit exposure limit increase from the Federal Reserve. Recovery and Resolution Planning As required by the Dodd-Frank Act, large domestic financial institutions, such as BNY, are required to submit periodically to the Federal Reserve and the FDIC a plan – referred to as the 165(d) resolution plan – for their rapid and orderly resolution in the event of material financial distress or failure. In addition, certain large IDIs, such as The Bank of New York Mellon, are required to submit periodically to the FDIC a separate plan for resolution in the event of the institution’s failure. The public portions of these resolution plans are available on the Federal Reserve’s and FDIC’s websites. BNY also maintains a comprehensive recovery plan, which describes actions it could take to seek to avoid failure if faced with financial stress. On June 20, 2024, the FDIC issued a final rule amending its resolution planning rule applicable to covered IDIs. The amended rule: (i) adjusts the frequency of resolution plan submissions by IDIs affiliated with a U.S. G-SIB, including The Bank of New York Mellon, from a 3-year cycle to a 2-year cycle; (ii) expands resolution plan content requirements; (iii) requires IDIs to provide the FDIC with notice within 45 days of certain “extraordinary events”; and (iv) revises certain definitions to be more consistent with similar concepts and approaches under the Dodd-Frank Act. The final rule became effective on Oct. 1, 2024 and was subsequently modified through a series of FAQs issued by the FDIC in 2025. On Dec. 31, 2025, the FDIC announced an update to IDI resolution planning requirements for FDIC-insured depository institutions with $50 billion or more in assets. The FDIC stated that covered IDI subsidiaries of G-SIBs that are scheduled to file full resolution submissions on or before July 1, 2026 (such as The Bank of New York Mellon) will instead be required to submit content equivalent to an interim supplement by that date. The Bank of New York Mellon submitted its last IDI resolution plan to the FDIC on Dec. 1, 2023. In 2019, the Federal Reserve and FDIC issued a final rule modifying certain requirements for the 165(d) resolution plan. The final rule requires U.S. G-SIBs, such as BNY, to file alternating full and more limited, targeted resolution plans every two years. The final rule does not materially modify the components or informational requirements of full resolution plans. The Federal Reserve and FDIC found no deficiencies or shortcomings in BNY’s 2023 full resolution plan submission. BNY submitted a targeted resolution plan on July 1, 2025, and the next full resolution plan submission is due on or before July 1, 2027. If the Federal Reserve and FDIC jointly determine that our 165(d) resolution plan is not credible, and we fail to address the deficiencies in a timely manner, the FDIC and the Federal Reserve may jointly impose more stringent capital, leverage or liquidity requirements or restrictions on our growth, activities or operations. If we continue to fail to adequately remedy any deficiencies, we could be required to divest assets or operations that the regulators 64 BNY Supervision and Regulation (continued) determine necessary to facilitate our orderly resolution. The resolution strategy set out in our 165(d) resolution plan is a single point of entry strategy, whereby certain key operating subsidiaries would be provided with sufficient capital and liquidity to operate in the event of material financial stress or failure, and only our parent holding company would file for bankruptcy. In connection with our single point of entry resolution strategy, we have established the IHC to facilitate the provision of capital and liquidity resources to certain key subsidiaries in the event of material financial distress or failure. These resources are incremental to resources already pre-positioned at the key subsidiaries. In addition, we have a binding support agreement in place that requires the IHC to provide that support. The support agreement required the Parent to transfer its intercompany loans and most of its cash to the IHC and requires the Parent to continue to transfer cash and other liquid financial assets to the IHC on an ongoing basis. BNY and the other U.S. G-SIBs are also subject to heightened supervisory expectations for recovery and resolution preparedness under Federal Reserve rules and guidance. The Federal Reserve incorporates reviews of our capabilities in respect of recovery and resolution preparedness as part of its ongoing supervision of BNY. In the European Economic Area (“EEA”) and in the UK, the Bank Recovery and Resolution Directive, as amended by the Bank Recovery and Resolution Directive II (“BRRD”), provides the legal framework for recovery and resolution planning, including a set of harmonized powers to resolve or implement recovery of in-scope institutions, such as EEA and UK subsidiaries of third-country banks. The UK transposed the BRRD into local legislation and regulation before the UK exit from the EU on Dec. 31, 2020, and this continues to be effective under the UK regulatory framework as “retained EU law.” The BRRD, as implemented in local law, gives relevant EEA and UK regulators various powers, including: (i) powers to intervene pre-resolution to require an institution to take remedial steps to avoid the need for resolution; (ii) resolution tools and powers to facilitate the resolution of failing entities, such as the power to “bail-in” the debt of an institution (including certain deposit obligations); (iii) the power to require a firm to change its structure to remove impediments to resolvability; and (iv) powers to require in-scope institutions to prepare recovery plans. Under the BRRD, resolution authorities (rather than the institutions themselves) are responsible for drawing up resolution plans based on information provided by relevant institutions. Under applicable rules, in-scope institutions are required to maintain a minimum requirement for their own funds (defined as regulatory capital) and eligible liabilities (“MREL”) that can be written down or bailed-in to absorb losses. MREL is set on a case-by-case basis for each institution and is applicable to certain EU- and UK-domiciled credit institutions and certain foreign subsidiaries subject to recovery and resolution planning. As a material subsidiary, BNY SA/NV is also subject to internal MREL. Rules on Resolution Stays for Qualified Financial Contracts The Agencies’ regulations require U.S. G-SIBs (and their subsidiaries and controlled entities) and the U.S. operations of foreign G-SIBs to amend their covered qualified financial contracts (“QFCs”), thereby facilitating the application of U.S. special resolution regimes as necessary. The regulations allow these G-SIBs to comply by amending covered QFCs (with the consent of relevant counterparties) using the International Swaps and Derivatives Association (“ISDA”) 2018 U.S. Resolution Stay Protocol, ISDA 2015 Universal Stay Protocol or by executing appropriate bilateral amendments to the covered QFCs. BNY entities, which have been confirmed to engage in covered QFC activities, have adhered to the Protocol and, where necessary, have executed bilateral amendments to cover QFCs. Insolvency of an Insured Depository Institution or a Bank Holding Company; Orderly Liquidation Authority Under the FDI Act, if the FDIC is appointed as conservator or receiver for an IDI, such as The Bank of New York Mellon or BNY Mellon, N.A., upon its insolvency or in certain other circumstances, the FDIC has the power to: •Transfer any of the depository institution’s assets and liabilities to a new obligor, including a newly BNY 65 Supervision and Regulation (continued) formed “bridge” bank without the approval of the depository institution’s creditors; •Enforce the terms of the depository institution’s contracts pursuant to their terms without regard to any provisions triggered by the appointment of the FDIC in that capacity; or •Repudiate or disaffirm any contract or lease to which the depository institution is a party, the performance of which is determined by the FDIC to be burdensome, and the disaffirmance or repudiation of which is determined by the FDIC to promote the orderly administration of the depository institution. In addition, under federal law, the claims of holders of domestic deposit liabilities and certain claims for administrative expenses against an IDI would be afforded a priority over other general unsecured claims, including claims of debt holders, in the “liquidation or other resolution” of such an institution by any receiver. As a result, regardless of whether the FDIC repudiates any debt obligations of The Bank of New York Mellon or BNY Mellon, N.A., the debt holders would be treated differently from, and could receive, if anything, substantially less than, the depositors of the bank. The Dodd-Frank Act created a resolution regime (known as the “orderly liquidation authority”) applicable to domestic systemically important financial companies that are not IDIs, including BHCs, such as the Parent, and their non-bank affiliates. Under the orderly liquidation authority, the FDIC may be appointed as receiver for the systemically important institution, and its failed non-bank subsidiaries, for purposes of liquidating the entity if, among other conditions, it is determined that the institution is in default or in danger of default, and the failure poses a risk to the stability of the U.S. financial system. In liquidations of failing financial institutions where the Dodd-Frank orderly liquidation authority applies, the orderly liquidation authority supplants the U.S. Bankruptcy Code and sets forth the powers of the FDIC as receiver and the rights and obligations of creditors and other parties who have dealt with the financial institution. The powers of the FDIC as receiver under the orderly liquidation authority were based on the powers of the FDIC as receiver for IDIs under the FDI Act. However, the provisions governing the rights of creditors under the orderly liquidation authority were modified in certain respects to reduce disparities with the treatment of creditors’ claims under the U.S. Bankruptcy Code. Nonetheless, substantial differences in the rights of creditors exist between these two regimes, including the right of the FDIC to disregard the strict priority of creditor claims in some circumstances, the use of an administrative claims procedure to determine creditors’ claims (as opposed to the judicial procedure utilized in bankruptcy proceedings), and the right of the FDIC to transfer assets or liabilities of the institution to a third party or a “bridge” entity. Depositor Preference in Bank Resolutions The FDIC applies a priority regime (“depositor preference”) for the distribution of receivership assets of a failed bank. Under the depositor preference regime, when a U.S. bank fails, the claims of a receiver of an IDI for administrative expenses and claims of holders of U.S. deposit liabilities (including foreign deposits that are payable in the U.S. as well as in a foreign branch of the depository institution) are afforded priority over claims of other unsecured creditors of the institution, including depositors in non-U.S. branches. As a result, such depositors could receive, if anything, substantially less than the depositors in U.S. offices of the depository institution. FDIC Deposit Insurance Our U.S. banking subsidiaries, including The Bank of New York Mellon and BNY Mellon, N.A., accept deposits, and those deposits have the benefit of FDIC insurance up to the applicable limit. The current limit for FDIC insurance for deposit accounts is $250,000 per depositor at each insured bank. Under the FDI Act, insurance of deposits may be terminated by the FDIC upon a finding that the IDI has engaged in unsafe and unsound practices, is in an unsafe or unsound condition to continue operations or has violated any applicable law, regulation, rule, order, condition imposed by the FDIC, or written agreement between the IDI and the FDIC. The FDIC’s Deposit Insurance Fund (“DIF”) is funded by assessments on IDIs. The FDIC assesses DIF premiums based on an IDI’s average consolidated total assets, less the average tangible equity of the IDI during the assessment period. For larger institutions, such as The Bank of New York Mellon and BNY Mellon, N.A., assessments are 66 BNY Supervision and Regulation (continued) determined based on CAMELS ratings and forward-looking financial measures to calculate the assessment rate, which is subject to adjustments by the FDIC, and the assessment base. Under the FDIC’s regulations, a custody bank, including The Bank of New York Mellon and BNY Mellon, N.A., may deduct from its assessment base 100% of cash and balances due from depository institutions, securities, federal funds sold, and securities purchased under agreement to resell with a Standardized Approach risk-weight of 0% and may deduct 50% of such asset types with a Standardized Approach risk-weight of greater than 0% and up to and including 20%. This assessment base deduction may not exceed the average value of deposits that are classified as transaction accounts and are identified by the bank as being directly linked to a fiduciary or custodial and safekeeping account. Following the bank failures in March 2023, the FDIC announced that, as required by the FDI Act, any losses to the DIF to support uninsured depositors would be recovered by a special assessment prescribed through regulation. Under the FDI Act, the FDIC has discretion with respect to the design and timeframe for any special assessment, which may be on IDIs, depository institution holding companies (with the concurrence of the Treasury Secretary), or both, as the FDIC determines to be appropriate. The FDIC may consider the types of entities that benefit from the action taken, economic conditions, the effects on the industry, and such other factors as the FDIC deems appropriate. On Nov. 16, 2023, the FDIC adopted a final rule, effective April 1, 2024, implementing a special assessment on IDIs to recover losses to the DIF associated with the 2023 closures of Silicon Valley Bank and Signature Bank. Under the rule, the FDIC will collect from each IDI a special assessment, based on the IDI’s estimated uninsured deposits (excluding the first $5 billion of estimated uninsured deposits applied at the banking organization level) as of Dec. 31, 2022, during an initial special assessment period of eight quarters that began in the first quarter of 2024. The special assessment is subject to periodic adjustment by the FDIC, including early cessation, extension or a potential one-time final special assessment for any shortfall to the DIF. On Dec. 16, 2025, the FDIC proposed an interim final rule, effective Dec. 19, 2025, reducing the special assessment, and providing for offsets to regular quarterly deposit insurance assessments for banks subject to the special assessment if the amount collected exceeds losses following (i) the resolution of litigation between the FDIC and SVB Financial Trust and (ii) the termination of the receiverships. We have recorded accruals and related adjustments for the estimate of the special assessment to noninterest expense starting in the fourth quarter of 2023 and through 2025. BHC as Source of Strength and Liability of Commonly Controlled Depository Institutions The Federal Reserve requires BHCs to act as a source of financial and managerial strength to their bank subsidiaries. BNY has a statutory obligation to commit resources to its bank subsidiaries in times of financial distress. In addition, any loans by BNY to its bank subsidiaries would be subordinate in right of payment to depositors and to certain other indebtedness of its banks. In the event of a BHC’s reorganization under the U.S. Bankruptcy Code, any commitment by the BHC to a federal bank regulator to maintain the capital of a subsidiary IDI will be deemed assumed by the bankruptcy trustee and entitled to priority of payment of the unsecured claim resulting from such commitment. Further, in certain circumstances, BNY’s IDI subsidiaries could be held liable for losses incurred by another BNY IDI subsidiary. In the event of impairment of the capital stock of one of BNY’s national bank subsidiaries or The Bank of New York Mellon, BNY, as the banks’ stockholder, could be required to pay such deficiency. Bank Transactions with Non-bank Affiliates Transactions between BNY’s banking subsidiaries, on the one hand, and the Parent and its non-bank subsidiaries and affiliates, on the other, are subject to certain restrictions, limitations and requirements, which include limits on the types and amounts of transactions (including extensions of credit and asset purchases by our banking subsidiaries) that may take place and generally require those transactions to be in good faith, at arm’s-length, and on market terms. In general, extensions of credit by a BNY banking subsidiary to any non-bank affiliate, including the Parent, must be secured by designated amounts of specified collateral and are limited in the aggregate to 10% of the relevant bank’s capital and surplus for transactions with a single affiliate and to 20% of the relevant bank’s capital and surplus for transactions with all affiliates. There are also limitations on BNY 67 Supervision and Regulation (continued) affiliate credit exposures arising from derivative transactions and securities lending and borrowing transactions. Acquisitions/Transactions by Banks or BHCs Federal and state laws impose notice and approval requirements for mergers and acquisitions involving depository institutions or BHCs. The Bank Holding Company Act of 1956, as amended by the Gramm-Leach-Bliley Act and by the Dodd-Frank Act (the “BHC Act”), requires the prior approval of the Federal Reserve for the direct or indirect acquisition by a BHC of more than 5% of any class of the voting shares or all or substantially all of the assets of a commercial bank, savings and loan association or BHC. In reviewing bank acquisition and merger applications, the bank regulatory authorities will consider, among other things, the competitive effect of the transaction, financial and managerial resources, including the capital position of the combined organization, convenience and needs of the community factors, including the applicant’s record under the Community Reinvestment Act of 1977 (the “CRA”), the effectiveness of the subject organizations in combating money laundering activities and the risk to the stability of the U.S. banking or financial system. In addition, prior Federal Reserve approval would be required for BNY to acquire direct or indirect ownership or control of any voting shares of a company with assets of $10 billion or more that is engaged in activities that are “financial in nature.” Anti-Money Laundering (“AML”) and the USA PATRIOT Act A major focus of governmental policy on financial institutions has been aimed at combating money laundering and terrorist financing. The USA PATRIOT Act of 2001 contains numerous AML requirements for financial institutions that are applicable to BNY’s bank, broker-dealer and investment adviser subsidiaries and mutual funds and private investment companies advised or sponsored by our subsidiaries. Those regulations impose obligations on financial institutions to maintain a broad AML program that includes internal controls, independent testing, compliance management personnel, training, and customer due diligence processes, as well as appropriate policies, procedures and controls to detect, prevent and report money laundering, terrorist financing and other suspicious activity, and to verify the identity of their customers. Certain of those regulations impose specific due diligence requirements on financial institutions that maintain correspondent or private banking relationships with non-U.S. financial institutions or persons. The Anti-Money Laundering Act of 2020 (“AMLA”), which amends the Bank Secrecy Act (“BSA”), was enacted to comprehensively reform and modernize U.S. AML laws. Among other things, the AMLA codifies a risk-based approach to AML compliance for financial institutions; requires the development of standards by the U.S. Department of the Treasury for evaluating technology and internal processes for BSA compliance; and expands enforcement- and investigation-related authority, including a significant expansion in the available sanctions for certain BSA violations and instituting BSA whistleblower incentives and protections. Financial Crimes Enforcement Network (“FinCEN”) FinCEN, a bureau of the U.S. Department of the Treasury, issued rules under the BSA that apply to covered financial institutions, including The Bank of New York Mellon and BNY Mellon, N.A., setting forth five pillars of an effective AML program: development of internal policies, procedures and related controls; designation of a compliance officer; a thorough and ongoing training program; independent review for compliance; and customer due diligence (“CDD”). CDD requires a covered financial institution to implement and maintain risk-based procedures for conducting CDD that include the identification and verification of any beneficial owner(s) of each legal entity customer at the time a new account is opened. Bank Secrecy Act Extended to Investment Advisers On Aug. 28, 2024, FinCEN adopted a final rule requiring certain investment advisers to establish anti-money laundering/countering the financing of terrorism (“AML/CFT”) programs pursuant to the BSA and to monitor for, and report, suspicious activity and currency transactions to FinCEN. Investment advisers will be required to apply their AML/CFT programs to all advisory services provided to all customers, except that they will be permitted to exclude mutual funds, certain bank- and trust company-sponsored collective investment funds, and other investment advisers subject to the rule. Among 68 BNY Supervision and Regulation (continued) other requirements, the AML/CFT program must (i) be risk-based, (ii) be reasonably designed to prevent the investment adviser from being used for money laundering, terrorist financing, or other illicit finance activities and to achieve compliance with applicable provisions of the BSA and regulations thereunder, (iii) provide for independent compliance testing, and (iv) designate responsible persons and ongoing training. The effective date has been extended to Jan. 1, 2028 and BNY will implement a program designed to meet the applicable regulatory requirements. NYSDFS Anti-Money Laundering and Anti-Terrorism Regulations The New York State Department of Financial Services (“NYSDFS”) issued regulations requiring regulated institutions, including The Bank of New York Mellon, to maintain a transaction monitoring program to monitor transactions for potential BSA and AML violations and suspicious activity reporting, and a watch list filtering program to interdict transactions prohibited by applicable sanctions programs. The regulations require a regulated institution to maintain programs to monitor and filter transactions for potential BSA and AML violations and prevent transactions with sanctioned entities. The regulations also require institutions to submit annually a board resolution or senior officer compliance finding confirming steps taken to ascertain compliance with the regulation. Privacy and Data Protection The privacy provisions of the Gramm-Leach-Bliley Act generally prohibit financial institutions, including BNY, from disclosing nonpublic personal financial information of consumer customers to third parties for certain purposes (primarily marketing) unless customers have the opportunity to “opt out” of the disclosure. The Fair Credit Reporting Act restricts information sharing among affiliates for marketing purposes. In the EU, privacy law is primarily regulated by the General Data Protection Regulation (“GDPR”). The GDPR contains enhanced compliance obligations and penalties for non-compliance. EU Artificial Intelligence Act On July 12, 2024, the EU’s Regulation on Artificial Intelligence (“AI Act”) was published in the Official Journal of the EU and came into force on Aug. 1, 2024. The AI Act will apply extraterritorially, impacting both EU and non-EU entities providing or deploying artificial intelligence systems in the EU or placing General-Purpose artificial intelligence models on the EU Market, and will impact BNY. The AI Act creates pan-EU regulation to manage the risks associated with the use of artificial intelligence, including with respect to financial services. The AI Act requires categorization of artificial intelligence systems into four risk levels depending on their potential to harm individuals or society (unacceptable risk, high risk, limited risk, and minimal risk) and imposes obligations depending on the risk categorization, which may include data governance, documentation and recordkeeping, human oversight, testing, cybersecurity, disclosure, regulatory notification or reporting, or training. In addition, the AI Act prohibits artificial intelligence that pose unacceptable risks that are abusive or contradict EU values, including artificial intelligence that may be manipulative, exploitive, or discriminatory. The individual provisions of the AI Act apply on a rolling basis from Feb. 2, 2025 to Aug. 2, 2027. BNY has evaluated the impact of the AI Act and has established an implementation program designed to operationalize the regulatory requirements. Cybersecurity Regulation The NYSDFS requires financial institutions regulated by NYSDFS, including The Bank of New York Mellon, to establish a cybersecurity program, adopt a written cybersecurity policy, designate a chief information security officer, address artificial intelligence risks related to cybersecurity, and have policies and procedures in place to ensure the security of information systems and non-public information accessible to, or held by, third parties. The NYSDFS rule also includes a variety of other requirements to protect the confidentiality, integrity and availability of information systems, including the annual delivery of a certificate of compliance. The Agencies have adopted a final rule imposing notification requirements for significant computer-security incidents on banking organizations. Under the final rule, a BHC, state member bank or national bank, including the Parent, The Bank of New York BNY 69 Supervision and Regulation (continued) Mellon and BNY Mellon, N.A., is required to notify the Federal Reserve or OCC, as applicable, within 36 hours after a computer-security incident that could: (i) result in the banking organization’s inability to deliver services to a material portion of its customer base, (ii) disrupt the banking organization’s lines of businesses the failure of which would result in material losses, or (iii) disrupt operations the failure of which would threaten the financial stability of the U.S. On July 26, 2023, the SEC adopted rules, effective on Sept. 5, 2023, requiring public companies, including the Parent, to disclose material cybersecurity incidents and details regarding their cybersecurity risk management, strategy and governance. Under the rules, public companies must disclose material cybersecurity incidents on Form 8-K. Disclosure of material incidents generally is due within four business days after a public company determines that a cybersecurity incident is material. On an annual basis, public companies must describe in their annual report on Form 10-K their processes for assessing, identifying, and managing, and management’s role and expertise in assessing and managing, material cybersecurity risks; whether any cybersecurity risks have materially affected or are reasonably likely to material affect the company; and the board of directors’ oversight of cybersecurity risks. SEC Amendments to Regulation S-P for Safeguarding of Customer Information On May 16, 2024, the SEC adopted amendments (the “S-P Amendments”) to Regulation S-P, which governs the safeguarding, treatment and disposal of customer records and information by certain financial institutions, to enhance the protection of customer financial information and establish a federal minimum standard for data breach notifications to affected individuals by brokers, dealers, investment companies, registered investment advisers and transfer agents (“S-P covered institutions”). The S-P Amendments: (i) extend certain requirements of Regulation S-P to transfer agents registered with the SEC or another appropriate regulatory agency; (ii) require S-P covered institutions to develop, implement, and maintain written policies and procedures for an incident response program that is reasonably designed to detect, respond to, and recover from unauthorized access to or use of customer information; (iii) set forth a data breach notification requirement that requires S-P covered institutions to notify affected individuals whose customer information was, or is reasonably likely to have been, accessed or used without authorization (subject to certain exceptions) within 30 days after the S-P covered institution becomes aware that unauthorized access to or use of customer information has, or is reasonably likely to have, occurred; (iv) broaden the group of customers whose information is protected; (v) address the use of service providers by S-P covered institutions; and (vi) codify an existing statutory exemption to the requirement to provide annual privacy notices to customers. The S-P Amendments became effective as of Aug. 2, 2024, and the compliance date for BNY was in December 2025. BNY evaluated the S-P Amendments and implemented a program designed to meet the applicable regulatory requirements. Sustainability A number of governments have proposed or enacted laws and regulations addressing climate disclosure. Published guidance from our regulators globally, including the NYSDFS, has focused on climate-related financial risk management, including with respect to, among other things, governance, policies and procedures, strategy, risk management, data and reporting, and scenario analysis. Conversely, the OCC, on March 31, 2025, and the FDIC and Federal Reserve, on Oct. 16, 2025, rescinded their respective previously issued guidance regarding climate-related risk. As the global regulatory framework for climate and sustainability-related disclosure and risk management practices continues to evolve, including potential expansion, contraction or streamlining of regulations, we continue to monitor developments and evaluate the potential impacts on our business and operations. For example, California enacted three statutes imposing extensive new climate-related disclosure obligations on certain companies doing business in California, which became effective on Jan. 1, 2024. The California Voluntary Carbon Markets Disclosure Act requires annual disclosure around the use and sale of voluntary carbon offsets, including to make emissions-related claims. The Climate Corporate Data Accountability Act (as updated in 2024, “SB 253”), which requires annual disclosure of greenhouse gas emissions beginning in August 2026, and the Climate-Related Financial Risk Act (as updated in 2024, “SB 261”), which requires publication of biennial reports disclosing climate- 70 BNY Supervision and Regulation (continued) related financial risks and the measures adopted to mitigate the disclosed risks beginning on Jan. 1, 2026. On Dec. 1, 2025, the California Air Resources Board (“CARB”) issued initial proposed regulations for SB 253 and SB 261, and set Feb. 26, 2026 as the date for a public hearing to consider the proposed regulations. However, the Ninth Circuit Court of Appeals stayed enforcement of SB 261 on Nov. 18, 2025. In the EU, 2025 marked the first reporting cycle under the Corporate Sustainability Reporting Directive (“CSRD”) requiring companies to disclose information about impacts, risks, and opportunities related to sustainability matters in accordance with the European Sustainability Reporting Standards (“ESRS”). BNY SA/NV published its first CSRD report in 2025 as part of its 2024 annual report. During 2025, the focus was on simplifying EU sustainability rules, including CSRD and the Corporate Sustainability Due Diligence Directive (“CSDDD”), which focuses on sustainability-related due diligence obligations. Directive (EU) 2025/794, published in April 16, 2025, and the provisionally agreed Directive simplifying certain corporate sustainability reporting and due diligence requirements (together, the so called “Omnibus” package), which will directly impact BNY’s sustainability obligations in the EU. The Omnibus package amends the applicability criteria to reduce the scope of companies subject to CSRD and CSDDD, simplifies firms’ obligations and extends the compliance dates. BNY is assessing the impact of the Omnibus package changes and expects that the changes will result in a reduction of BNY companies required to comply with CSRD and CSDDD obligations. Additionally, reporting under Regulation (EU) 2020/852 (the “Taxonomy Regulation”) has been simplified. Amending Delegated Regulation (EU) 2026/73, published Jan. 8, 2026, simplifies Taxonomy reporting templates, reduces data requirements and provides a conditional two-year reporting relief. BNY SA/NV has been reporting under the Taxonomy Regulation since 2022 and will apply the simplification for its 2025 financial year reporting. Our UK supervisory authorities have adopted disclosure requirements and supervisory expectations that currently apply or will apply to our subsidiaries and branches that are regulated by the UK Financial Conduct Authority (“FCA”) and the UK Prudential Regulation Authority (“PRA”). For example, since the end of 2021 our PRA regulated branch and banking subsidiary have been subject to the PRA’s supervisory expectations for the management of climate-related financial risks, including as regards governance, risk management, scenario analysis and disclosure. On Dec. 3, 2025, the PRA updated its 2021 supervisory expectations regarding climate-related risk disclosure in Supervisory Statement 5/25, Enhancing banks’ and insurers’ approaches to managing climate-related risks. Further, FCA rules on anti-greenwashing, applicable from May 31, 2024, require that any sustainability-related claims made about our products and services by our FCA regulated entities are consistent with the sustainability characteristics of such products or services and are fair, clear and not misleading. On Nov. 20, 2025, the European Commission published its proposals for the Sustainable Finance Disclosures Regulation (“SFDR”) 2 which will replace the current SFDR and, as proposed, will significantly change the current SFDR regime. SFDR is an EU regulatory regime which requires financial market participants in the EU to make certain mandatory disclosures around how sustainability is integrated into their investment process and requires additional disclosures for certain financial products depending on their sustainability credentials. These new categories will be subject to specific requirements including in relation to minimum investment commitment and mandatory exclusions. The proposal is progressing through the EU legislative process and is subject to change. SFDR 2 is anticipated to come into force in 2027 or 2028. BNY is assessing the impact of the changes. Certain governments or regulators have enacted or implemented, or have proposed to enact or implement, statutes, regulations or policies that prohibit financial institutions from denying or canceling products or services to a person, or otherwise discriminating against a person in making available products or services, on the basis of social credit scores and certain other sustainability factors. On Oct. 7, 2025, the OCC and FDIC issued proposed rules to codify the elimination of reputation risk from their supervisory programs. That same day, those BNY 71 Supervision and Regulation (continued) agencies also issued proposed rules to establish a uniform definition for the term “unsafe or unsound practice” for the purposes of such agencies’ enforcement and supervisory authority. Incentive Compensation Arrangements Section 956 of the Dodd-Frank Act requires six federal regulators to jointly prescribe regulations or guidelines regarding incentive-based compensation practices at certain financial institutions, including BNY. The timeframe for a joint proposal and implementation of a final rule, if any, is currently unknown. Regulated Entities of BNY and Ancillary Regulatory Requirements BHC and Bank Entities BNY is registered as an FHC under the BHC Act and subject to supervision by the Federal Reserve. In general, the BHC Act limits an FHC’s business activities to banking, managing or controlling banks, performing certain servicing activities for subsidiaries, engaging in activities incidental to banking, and engaging in any activity, or acquiring and retaining the shares of any company engaged in any activity, that is either financial in nature or complementary to a financial activity and does not pose a substantial risk to the safety and soundness of depository institutions or the financial system generally. A BHC’s ability to maintain FHC status is dependent on: (i) its U.S. IDI subsidiaries qualifying on an ongoing basis as “well capitalized” and “well managed” under the prompt corrective action regulations of the appropriate regulatory agency (discussed above under “Prompt Corrective Action”); (ii) the BHC itself qualifying on an ongoing basis as “well capitalized” and “well managed” under applicable Federal Reserve regulations; and (iii) its U.S. IDI subsidiaries’ continuing to maintain at least a “satisfactory” rating under the CRA. The Federal Reserve’s rating system for the supervision of large financial institutions (“LFIs”) applies to, among other entities, all BHCs with total consolidated assets of $100 billion or more, including BNY. The LFI rating system includes a four-level rating scale and three component ratings. The four levels are: Broadly Meets Expectations; Conditionally Meets Expectations; Deficient-1; and Deficient-2. The component ratings are assigned for: Capital Planning and Positions; Liquidity Risk Management and Positions; and Governance and Controls. A firm must be rated “Broadly Meets Expectations” or “Conditionally Meets Expectations” for each of its component ratings to be considered “well managed.” On Nov. 5, 2025, the Federal Reserve finalized changes to its supervisory rating framework for LFIs. The recent changes modify the “well managed” determination: a firm may be considered “well managed” even if one component is rated Deficient-1, provided the other two components are rated Broadly Meets Expectations or Conditionally Meets Expectations; however, a Deficient-2 rating in any component disqualifies a firm from being considered “well managed.” Statutes and regulations promulgated by the Federal Reserve permit additional activities and prescribe expedited procedures, or provide other benefits for “well managed” firms. See “U.S. Capital Rules – Leverage Ratios” and “Prompt Corrective Action Regarding IDI Capital Requirements” above for details on qualifying as “well capitalized”. An FHC that does not continue to meet all the requirements for FHC status will, depending on which requirements it fails to meet, lose the ability to undertake new activities, continue current activities, or make acquisitions that are not generally permissible for BHCs without FHC status. As of Dec. 31, 2025, BNY and our U.S. bank subsidiaries were “well capitalized” based on the ratios and rules applicable to them. On Nov. 18, 2025, the Federal Reserve released a memorandum outlining a revised Statement of Supervisory Principles. The Statement emphasized the Federal Reserve’s focus on material financial risks to firms, as opposed to processes, procedures, and documentation that do not pose a material risk to safety and soundness. The Bank of New York Mellon, BNY’s largest banking subsidiary, is a New York state-chartered bank, a member of the Federal Reserve and subject to regulation, supervision and examination by the Federal Reserve, the FDIC and the NYSDFS. BNY’s national bank subsidiaries, BNY Mellon, N.A. and The Bank of New York Mellon Trust Company, National Association, are chartered as national banking associations subject to primary regulation, supervision and examination by the OCC. 72 BNY Supervision and Regulation (continued) Digital Assets The regulatory environment for digital assets continues to evolve. In the U.S., recent federal developments support the responsible use of digital assets, including the OCC’s and FDIC’s guidance that a range of crypto-related activities are permissible in the federal banking system. In both the EU and the UK, public authorities are taking initiatives to amend legal and regulatory frameworks in order to facilitate the development of markets in digital assets. BNY continues to evaluate the impacts of regulators’ guidance applicable to its digital asset capabilities, including the SEC, Federal Reserve, OCC, FDIC and NYSDFS. Securities Markets We operate a number of broker-dealers that engage in securities underwriting and other broker-dealer activities in the U.S. These companies are SEC-registered broker-dealers and members of Financial Industry Regulatory Authority, Inc. (“FINRA”), a securities industry self-regulatory organization. BNY’s non-bank subsidiaries engaged in securities-related activities are regulated by supervisory agencies in the countries in which they conduct business, where required. Certain of BNY’s public finance and advisory activities are regulated by the Municipal Securities Rulemaking Board. Certain of BNY’s subsidiaries are registered with the CFTC as commodity pool operators, introducing brokers and/or commodity trading advisors and, as such, are subject to CFTC regulation. The Bank of New York Mellon is registered as a swap dealer (as defined in the Dodd-Frank Act) with the CFTC and is a member of the National Futures Association (“NFA”) in that same capacity. As a swap dealer, The Bank of New York Mellon is subject to regulation, supervision and examination by the CFTC and NFA. On Dec. 13, 2023, the SEC approved a final rule requiring covered clearing agencies that clear transactions in U.S. Treasuries (“CCPs”) to establish policies requiring their direct participants, including BNY, to submit for clearing all “eligible secondary market transactions” in U.S. Treasuries to which such direct participant is a counterparty, which include all repurchase and reverse repurchase agreements (“repo”) collateralized by U.S. Treasuries and certain cash transactions in U.S. Treasuries engaging specific institutions, including inter-dealer brokers, registered broker-dealers, government securities brokers and government securities dealers. Eligible secondary market transactions, however, exclude (i) repo transactions with affiliates (under certain conditions), central banks, sovereign entities, international financial institutions, natural persons and CCPs and (ii) securities lending transactions involving U.S. Treasuries. The compliance date for all eligible cash market transactions is Dec. 31, 2026 and the compliance date for all eligible repo market transactions is June 30, 2027. SEC Rules Impacting Investment and Wealth Management SEC regulations impose requirements on mutual funds, exchange-traded funds and other registered investment companies (“RICs”) under the 1940 Act. Among other things, these rules require mutual funds (other than money market funds) to provide portfolio-wide and position-level holdings data to the SEC on a monthly basis. The regulations also impose liquidity risk management requirements that are intended to reduce the risk that funds will not be able to meet shareholder redemptions and to minimize the impact of redemptions on remaining shareholders. On Sept. 20, 2023, the SEC adopted amendments expanding the scope of terms that the SEC considers materially deceptive and misleading in a fund’s name without a corresponding policy and related controls to invest at least 80% of the fund’s net asset value (plus certain borrowings) in the manner suggested by the fund’s name (“80% Policy”), including names that reference “growth” or “value,” or a name indicating that investment decisions incorporate any environmental, social and governance factors. The SEC extended the compliance dates and fund groups have until June 11, 2026 or Dec. 11, 2026 to come into compliance, depending upon their net asset size. SEC Rule 6c-11 (the “ETF Rule”) under the 1940 Act permits exchange traded funds (“ETFs”) that satisfy certain conditions to organize and operate without first obtaining an exemptive order from the SEC and requires an ETF to make certain disclosures, including historical data on an ETF’s premiums, BNY 73 Supervision and Regulation (continued) discounts and bid-ask spread information, as well as the ETF’s daily portfolio holdings. The ETF Rule also requires ETFs using custom baskets to put written policies and procedures in place establishing that the custom baskets are in the best interests of the ETF and its shareholders. Pursuant to the ETF Rule, BNY has launched a number of ETFs. Certain of our subsidiaries are RIAs, and as such are supervised by the SEC. They are also subject to various U.S. federal and state laws and regulations and to the laws and regulations of any countries in which they conduct business. Our subsidiaries advise both RICs, including the BNY Mellon Family of Funds and BNY Mellon ETF Funds, and private investment companies which are not registered under the 1940 Act. Certain of our investment management, trust and custody operations provide services to employee benefit plans that are subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), administered by the U.S. Department of Labor. ERISA imposes certain statutory duties, liabilities, disclosure obligations and restrictions on fiduciaries, as applicable, related to the services being performed and fees being paid. SEC Regulation Best Interest (“Reg BI”) requires a broker-dealer to act in the “best interest” of a retail customer when making a recommendation of any securities transaction or investment strategy to any such customer. The Form CRS Relationship Summary (“Form CRS”) requires RIAs and broker-dealers to provide retail investors with a brief summary about the nature of their relationship with their investment professional and supplements other more detailed disclosures. Operations and Regulations Outside the U.S. We maintain a presence in the UK through the London branch of The Bank of New York Mellon, The Bank of New York Mellon (International) Limited (a credit institution incorporated and authorized in the UK), and a number of our investment firms. We maintain a presence in the EU through the Frankfurt branch of The Bank of New York Mellon, BNY SA/NV, which is headquartered in Belgium and has a branch network in a number of other EU countries, and through certain of our investment firms. BNY SA/NV is a public limited liability company incorporated under the laws of Belgium, holds a banking license issued by the National Bank of Belgium and is authorized to carry out all banking and savings activities as a credit institution. The European Central Bank (the “ECB”) has responsibility for the direct supervision of significant banks and banking groups in the Euro area, including BNY SA/NV. The ECB’s supervision is carried out in conjunction with the relevant national prudential regulator (the National Bank of Belgium in BNY SA/NV’s case), as part of the Single Supervisory Mechanism. BNY SA/NV conducts its activities in Belgium as well as through its branch offices in Denmark, France, Germany, Ireland, Italy, Luxembourg, the Netherlands, Poland and Spain. In Europe, branches of The Bank of New York Mellon are subject to regulation in the countries in which they are established, in addition to being subject to oversight by BNY’s U.S. regulators. Certain of our financial services operations in the UK are subject to regulation and supervision by the FCA and the PRA. The PRA is responsible for the authorization and prudential regulation of firms that carry on PRA-regulated activities, including banks. PRA-authorized firms are also subject to regulation by the FCA for conduct purposes. In contrast, FCA-authorized firms (such as investment management firms) have the FCA as their sole regulator for both prudential and conduct purposes. As a result, FCA-authorized firms must comply with FCA prudential and conduct rules and the FCA’s Principles for Businesses, while dual-regulated firms must comply with the FCA conduct rules and FCA Principles, as well as the applicable PRA prudential rules and the PRA’s Principles for Businesses. The PRA regulates The Bank of New York Mellon (International) Limited, our UK-incorporated bank, as well as the London branch of The Bank of New York Mellon. Certain of BNY’s UK-incorporated subsidiaries are authorized to conduct investment business in the UK. Their investment management advisory activities and their sale and marketing of retail investment products are regulated by the FCA. Certain UK investment funds, including investment funds of BNY, are registered with the FCA and are offered for sale to retail investors in the UK. The types of activities in which the foreign branches of our banking subsidiaries and our international subsidiaries may engage are subject to various 74 BNY Supervision and Regulation (continued) restrictions imposed by the Federal Reserve. Those foreign branches and international subsidiaries are also subject to the laws and regulatory authorities of the countries in which they operate and, in the case of banking subsidiaries, may be subject to regulatory capital requirements in the jurisdictions in which they operate. The primary prudential framework in the EU is provided by the Capital Requirements Directive (“EU CRD”) and Capital Requirements Regulation (“EU CRR”), both of which implement many elements of the Basel III framework. On July 9, 2024, the texts of the EU Capital Requirements Regulation 3 (“CRR3”) and Capital Requirements Directive 6 (“CRD6”) came into effect and will be implemented in phases through to January 2027. Through these regulations, the EU will implement the Basel 3.1 standards via amendments to EU CRD and CRR. These changes will affect the operations of BNY SA/NV (including capital and liquidity requirements) and the Frankfurt branch of The Bank of New York Mellon (including a capital endowment requirement and additional governance, reporting and supervisory obligations). In addition, Article 21c of CRD6 will restrict the provision of prescribed core banking services by non-EU entities to EU clients, except where these services are provided through an authorized EU branch or where an exemption applies. BNY is monitoring EU Member State transposition of the text of Article 21c into national law and will continue to assess the impact of the restriction on its operations as further clarity on Member State implementation, regulatory guidance, and supervisory expectations develop. The UK’s version of the EU Capital Requirements Regulation (“UK CRR”) provides the prudential framework for credit institutions in the UK. Aspects of UK CRR are currently proposed to be amended as part of the PRA’s plans to implement the Basel 3.1 standards in the UK. The amended rules, which will be relevant to the operations of The Bank of New York Mellon (International) Limited, are set to apply from Jan. 1, 2027. In the EU, the Investment Firms Directive/Investment Firms Regulation (“IFD/IFR”) is the EU’s prudential regime for investment firms. The UK has implemented its version of the IFD/IFR via the UK Investment Firms Prudential Regime (“UK IFPR”). Under both IFD/IFR and UK IFPR, the capital requirements for most investment firms are based on factors that are more tailored to the risks that investment firms face, rather than Basel standards for banks such as credit risk, market risk or operational risk. BNY has several EU- and UK-domiciled investment firms that are subject to IFD/IFR and UK IFPR, respectively. In addition, various proposed changes to regulations in both the EU and the UK may impact our business. In the EU, the European Commission has announced a number of initiatives, such as the Market Integration Package, the Retail Investments Strategy, and the Savings and Investments Union, which may result in regulatory changes. In the UK the Government’s Mansion House Reforms and Leeds Reforms packages, aimed at increasing investment in, and the competitiveness of, the UK economy, will continue to result in changes to regulations affecting BNY’s operations. Under the UK’s Smarter Regulatory Framework, the UK Government continues to migrate EU-derived financial services laws into the UK’s Financial Services and Markets Act (“FSMA”) based regime. On Feb. 12, 2025, the European Commission proposed a framework to facilitate a coordinated EU/EEA transition to a T+1 settlement cycle on Oct. 11, 2027. On Oct. 14, 2025, Regulation (EU) 2025/2075 of the European Parliament and Council was published in the Official Journal of the EU, amending the Central Securities Depositories Regulation (Regulation (EU) No 909/2014) to shorten the settlement cycle for EU transactions in transferable securities from two business days (T+2) to one business day after the trade date (T+1) from Oct. 11, 2027. On Feb. 19, 2025, the UK government confirmed that the UK will transition to a T+1 standard for settling securities on Oct. 11, 2027. On Nov. 20, 2025, the UK Government published a draft of The Central Securities Depositaries (Amendment) (Intended Settlement Date) Regulations 2026, alongside a policy note mandating the UK’s transition to a T+1 standard for settling securities on Oct. 11, 2027. The proposals in the UK, EU, and EEA remain subject to final legislation and regulation. As a result of the transition to T+1 settlement across European jurisdictions, BNY will be required to implement a range of technical and operational updates. BNY continues to assess the impact of these transitions on its business and operations. BNY 75 Supervision and Regulation (continued) The lines of business included in our Securities Services, Market and Wealth Services and Investment and Wealth Management business segments are subject to significant regulation in numerous jurisdictions around the world relating to, among other things, the safeguarding, administration and management of client assets and client funds. BNY continues to assess the impact of the forthcoming changes outlined above on its operations. Operational Resilience in Europe The EU’s Digital Operational Resilience Act (“DORA”)’s compliance date was Jan. 17, 2025 and harmonizes operational resiliency requirements across the EU. DORA is broadly aligned with the BCBS’s Principles for Operational Resilience, with a focus on reducing risk of failure of information and communication technology and the risk related to financial entities’ dependencies on these items. DORA requires financial entities operating in the EU, including BNY SA/NV and the Frankfurt branch of The Bank of New York Mellon to establish an information and communications technology risk management framework, including monitoring and testing, incident response, business continuity, and third-party risk management. The UK’s operational resilience regime requires in-scope firms to identify “important business services” critical to operations, map necessary resources, processes and information to deliver the critical services, establish maximum disruption impact tolerances and related testing, maintain a communication strategy, and document the processes in policies and procedures. Banks and branches operating in the UK, including the London branch of The Bank of New York Mellon and The Bank of New York Mellon (International) Limited, were required to finalize implementation of PRA and FCA requirements on operational resilience by March 31, 2025. Funds Regulation in Europe The Alternative Investment Fund Managers Directive (the “AIFMD”) has a direct effect on our alternative fund manager clients and our depository business and other products offered across Europe as well as upon our Investment Management business. AIFMD imposes heightened obligations upon depositories, which have operational effects. Our businesses servicing regulated funds in Europe and our Investment Management businesses in Europe are also affected by the revised directive governing the Directive on Undertakings for Collective Investment in Transferable Securities (“UCITS V”). Under the regulations for depositary safekeeping duties under the AIFMD and UCITS V, the European Commission recognizes the use of omnibus account structures when accounting for assets in a chain of custody, but requires that depositaries and trustees, such as BNY, maintain their own books and records. On April 15, 2024, an EU directive amending the AIFMD and UCITS V entered into force (known as “AIFMD II” or the “Omnibus Directive”). The revised AIFMD II regime introduces updated rules for depositaries, a new loan origination framework, and liquidity management rules for alternative investment funds (“AIFs”). The Omnibus Directive also provides a new framework governing the use of liquidity management tools for UCITS. EU Member States have until April 2026 to implement the relevant changes under AIFMD II/the Omnibus Directive into their national laws. BNY is assessing the impact of the changes on its business. 76 BNY